Drum It Up! Steel Drum Industry News, Trends, and Issues

Archive for the ‘DOT/UN’ Category

Drum Components that are UN Certified are not Interchangeable.

March 17th, 2020 by Howard Skolnik

Filed under: DOT/UN, Safety, Skolnik Newsletter

While steel drums may look alike, once they are United Nations certified for hazardous materials, they are as unique as the manufacturer. The entire design of a UN drum, and all its components (metal thickness of the body and heads, ring type, gasket, bolt, nut, plugs), is set and defined when being subjected to the Performance Oriented Packaging Standards per CFR 178.600, the US Code of Federal Regulations. The specific components used to perform the test comprise a drum type, or certification, that must meet a designated test standard for classified HazMat products. Once in the field, shippers cannot alter or interchange any of these components, even though they may appear similar, changing these features will impact the ability of the drum to perform as certified. This also applies to the required Closure Instructions per CFR 178.2(c), which are required to be given to the shipper by the specific packaging manufacturer. If replacement parts are needed, fillers must make sure that they get the originally tested components from the manufacturer. Once a drum enters transportation, compliance with the UN Certification is the responsibility of the shipper. Failure to comply with the UN certification may result in a fine from the DOT.

Pack it Right! Ship it Right!

February 25th, 2020 by Howard Skolnik

Filed under: Associations, DOT/UN, HazMat, Safety

A compliant shipment of dangerous goods has never been more critical, more complex and more expensive if done improperly. In addition to lives at risk, planes, ships, trains, trucks and all public right-of-way can be severely impacted when an incident does occur. In order to educate shippers on how to identify, pack and ship hazardous materials, many agencies and industry partners are developing resources to provide the latest in safety regulation as well as videos and tools on how to transport products safely. The Council on Safe Transport of Hazardous Articles (COSTHA), has gathered this information and created a web page that is an outstanding resource for learning about compliant shipping of dangerous goods / hazardous materials. Check out the webpage and learn how you can help to ensure that regulated shipments in commerce are properly prepared.

Get Ready to Receive a DOT Inspection

February 18th, 2020 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

If you are shipping or receiving any type of dangerous goods or hazardous materials, it is likely that one day, when you are in the midst of a special project, a DOT inspector could show up at your front door and begin the formal Inspection process. The inspection will include validation of your hazmat employee training, tool calibration, product certification testing and much more. Some people believe that if this happens, you are to try to evade the inspector, say you are on vacation or just lie and say you are not there. In fact, this is the worst thing that you can do, and frankly, if you have prepared for the visit, you should be able to confidently welcome the inspector into your company. To be prepared, the Council on the Safe Transport of Hazardous Articles (COSTHA) is offering a NEW and REVISED free booklet of suggestions that will help you prepare for the visit. Before an inspection, all companies should establish and define procedures for dealing with any regulatory inspector when they arrive.
For a free copy of the revised booklet, Click Here.

Rogue Lithium Battery Shipments Under Scrutiny

January 21st, 2020 by Howard Skolnik

Filed under: DOT/UN, HazMat, Industry News, Safety, Skolnik Newsletter

The International Air Transport Association (IATA), in partnership with the Global Shippers Forum (GSF), the International Federation of Freight Forwarders Associations (FIATA) and the International Air Cargo Association (TIACA), are amplifying their efforts to ensure the safe air transport of lithium batteries. The organizations are also renewing calls for governments to crack down on manufacturers of counterfeit batteries and of mis-labeled and non-compliant shipments introduced into the supply chain, by issuing and enforcing criminal sanctions on those responsible. But, we are seeing an increase in the number of incidents in which rogue shippers are not complying. The industry is initiating a campaign to raise awareness of the need to comply. The campaign includes four specific initiatives:

  1. New incident reporting and alert system for airlines: Creating an industry information sharing platform that will allow real-time information about dangerous goods incidents to be reported.
  2. Industry awareness campaign on the dangers of shipping undeclared and misdeclared lithium batteries: A series of dangerous goods awareness seminars has been developed in collaboration with the World Customs Organization (WCO).
  3. Facilitation of a joined-up industry approach: The adoption of a cross-domain approach to include aviation security, manufacturing standards, customs and consumer protection agencies. Currently air cargo is scanned for items that pose a risk to security such as explosives, but not for items such as lithium batteries.

    Responsible shippers rely on government enforcement of standards to protect their investment in training and safe operating procedures. Air freight remains a vital link in international supply chains and it is essential that the rules for ensuring the safe movement of all cargoes are understood and acted on by all parties involved. Safety is aviation’s top priority.

  4. Passengers traveling with Lithium Batteries: Lithium batteries carried by passengers remain a safety focus for airlines. Portable Electronic Devices (PEDs) guidance is available to travelers in eight languages detailing what items must be packed in carry-on baggage.

Tired of Reading Closure Instructions? Try Our New Videos

December 17th, 2019 by Howard Skolnik

Filed under: DOT/UN, Safety, Skolnik Newsletter

Even though you may be purchasing a drum that meets the United Nations criteria for shipping hazardous materials, the proper closure of the drum is the final and most important part of the regulation. In fact, the US Code of Federal Regulations, Title 49, paragraph 178.2(c), requires that packaging manufacturers give current written instruction to the fillers about the proper closure procedure for their “manufacturer-specific” packaging. Closure Instructions are not generic. In addition, current instructions must be kept on file in the event that a filler/shipper receives a DOT Authorization Inspection.

While every SKOLNIK order is shipped with written Closure Instructions, we now have a new set of videos that illustrate the closure process for drums with bolt ring closures, leverlock closures and the 2” and 3/4” plug closure. Check them out at www.Skolnik.com and scroll down to the CLOSURE INSTRUCTION VIDEOS. We hope you enjoy the music too!

Written Closure Instructions are also available in English and Spanish at: https://www.skolnik.com/closure-instructions. Need further clarification or would like to receive a copy of the Closure Instructions that apply to your specific Skolnik shipment? Call or email us.

BACK-OFF Prevention Addressed in Canada

November 26th, 2019 by Howard Skolnik

Filed under: Associations, DOT/UN, HazMat, Industry News, Skolnik Newsletter

For many years, during DOT audits, customers are often asked to provide technical information regarding the prevention of the closure plug Back-Off. By definition, Back-Off refers to the potential loosening of a steel or synthetic drum plug (usually the 2” and the ¾” on the top head) after the required torque is reached when closing a drum. Currently, CFR 49, 173.227(b)(2)(ii) does state that the screw closures must be “physically held in place by any means capable of preventing back-off or loosening of the closure by impact or vibration during transportation.” Transport Canada still refers to this requirement as “closures that are threaded.” However, in a move to have Transport Canada harmonize with the US CFR, COSTHA (The Council on the Safe Transport of Hazardous Articles) has submitted a proposed revision to Transport Canada. The proposal expands the criteria so that the “inner packagings shall have closures with gaskets and which shall either be threaded or physically held in place by any means capable of preventing back-off or loosening of the closure by impact or vibration during transport.”

For information about meeting the Back Off requirement, Skolnik offers solutions to securing closures plugs.