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

Archive for the ‘DOT/UN’ Category

Renewal of “M” Numbers

May 17th, 2022 by Jon Stein

Filed under: Associations, DOT/UN, Skolnik Newsletter

At the recent Reusable Industrial Packaging Association (RIPA) Technical Meeting in Memphis, Tennessee, an update was provided to RIPA members on recent changes:

  1. Beginning in November 2017, U.S. DOT began putting registered “M” numbers on a 5-year cycle for renewal.
  2. M-Number holders were given one year to write into DOT and preserve their number(s). RIPA assisted its members in fulfilling this task.
  3. Reconditioner numbers (“R” Numbers and “Registered Symbols” were allowed to continue for the purpose of marking packaging).
  4. Members were advised to look for correspondence from DOT re-establishing their M Number(s), as many are coming due for renewal in late 2022 and early 2023.

The RIPA meeting was well attended and featured an outstanding presentation by Bill Schoonover, PHMS OHMS, on “DOT Looks to the Future of Regulation”.

PHMSA SEEKING COMMENTS

March 29th, 2022 by Howard Skolnik

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

PHMSA and the U.S. Nuclear Regulatory Commission are jointly seeking comments on issues concerning requirements in the International Atomic Energy Agency (IAEA) regulations for the safe transport of radioactive materials. The IAEA is considering revisions to their regulations as part of its periodic review cycle for a new edition. These changes may or will “run downstream” and can impact regulated transport under the 49 CFR and other modal regulations. Interested parties may wish to explore this subject and contribute. Submit comments by March 4, 2022. Find out how right here.

Do Your Employees Need Hazmat Training?

February 22nd, 2022 by Howard Skolnik

Filed under: DOT/UN, HazMat, Skolnik Newsletter

The U.S. Department of Transportation requires every hazmat employer to provide one or several types of training to hazmat employees that perform hazmat transportation functions. Industrial packaging manufacturers, reconditioners, distributors and shippers that cause packagings of hazardous materials to be shipped in transportation, are considered hazmat employers. A hazmat employee is a part-time or full-time employee whose job responsibility “…directly affects hazardous materials transportation.” There are several tiers of training that may apply to your business facilities. They are:

General awareness. This basic level of training applies to all covered employees and includes and is intended to familiarize employees with the basic requirements of the Hazardous Materials Regulations.

Function specific. This secondary training level applies to employees performing key job functions, such as applying markings to containers or operating the leakproofness tester.

Safety. All hazmat employees must receive safety training concerning how to respond to emergency situations; how to protect themselves from exposures to hazmat; and procedures for avoiding accidents. If you provide OSHA, EPA or other training on these subjects, you are not required to re-train employees.

Security awareness training. All employees should receive some basic plant security information, which is required as part of this training level. This training need not be extensive   as it might be for a chemical facility, for example   but be sure to inform your employees about security access points, etc.

In-depth security training. If your plant is required to develop and maintain a security plan, employees must be aware of the plan and its contents.
When must hazmat employee training take place? All new employees performing hazmat functions, and employees that change jobs in a company and become a hazmat employee, must be trained within 90 days. Even though the regulations state that during the initial 90-day period newly hired employees may work in the plant if they are directly supervised. However, hazmat employees are subject to training once they begin actively working.

Testing. DOT requires employers to maintain proof (“certification”) that every hazmat employee has been trained and tested. Be sure your training certificates are dated and signed by the employee and the person doing the training.

Record keeping. Training records must be maintained for each covered employee and be retained for as long as the employee works for the company, and 90 days thereafter.

Steel Drums Reign

January 25th, 2022 by Howard Skolnik

Filed under: DOT/UN, HazMat, Skolnik Newsletter

Usage of steel drums continues to defy contenders as being the most reliable packaging for the shipment of dangerous goods. However, while the popularity is sustained, there are some manufacturers that are offering reduced metal thickness in order to offset steel price increases. The result is that while these thin gauge steel drums are able to marginally qualify for the minimal requirements of the DOT and UN certification, they do not perform as well in-field. Gone are the days of drum failures due to seam leaks — today’s most common incidents are related to fork-lift puncture and material handling. This change in the type of incidents, and the reduction of metal thickness leads one to conclude that these thin walled drums might be paving the way for a new set of in-transit incidents. Furthermore, shippers of steel drums fail to realize the g-forces associated with steel drum shipments and often ignore, or underestimate, adequate blocking and bracing preparation. CFR49 173.28(4)(i) states that for steel drums intended for reuse, 0.92mm is the minimum allowable steel gauge or a 0.82 body is allowed if the heads are 1.11mm. Even at these minimum levels, we recommend that thicker options are preferred because of the reduced risk of the transport package. Don’t risk the loss of your expensive contents in order to save a few cents a pound on the steel.

Avoid Invalidation of UN Certification

January 18th, 2022 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

UN packagings are fabricated and tested to specific levels of performance. These tests allow a manufacturer to mark the packaging with the appropriate testing criteria (eg: packing group, maximum gross weight, contents). Often, users innocently alter the integrity of the package by adding accessories (eg: a plastic liner) or by replacing accessories with different components (eg: closure ring, gasket) in which case, the certification of the package can be voided if not re-tested for qualification. “A different packaging” is defined in CFR49 178.601(c)(4) as a packaging that differs from a previously produced packaging in structural design, size, material of construction, wall thickness or manner of construction. Further design qualification testing is not required if the alterations to the packaging do not constitute “a different packaging.” Also, Closure Instructions are packaging specific and must be used only for the packagings as designated.

Choosing a Packaging is More Than Just an “X” Rating!

November 16th, 2021 by Howard Skolnik

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

When shipping dangerous goods, only the shipper knows the potential perils that a packaging might face. Many in industry assume that if they are in possession of UN tested packaging and a packaging test certificate, they have met the requirements of the regulations concerning the packaging of dangerous goods. However, nothing could be farther from the truth! The UN requirements state that in addition to the appropriate packaging test selection, shippers should consider the mode of transport as well as conditions of climate when choosing a packaging. Failure to select the right package for a journey is often the result of shippers assuming that UN packages will perform their job unimpeded. Although the principal cause of leaks in transport is usually due to handling, initial package selection for other types of failures is critical. Therefore, when purchasing a packaging, specifically a steel drum, a shipper must request more from a drum supplier than “I want an X drum for a product.” The shipper should request “ an X rated drum for a product which will be shipped all over the world and needs a packaging that will minimally meet the UN criteria and will not be unduly affected by vibration, temperature, pressure, various types of handling equipment, and the like.” In all, the selected package must be able to successfully transport the contents safely to their destination. A cushion of safety is wise to incorporate into every drum purchase.