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

Archive for the ‘DOT/UN’ Category

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.

What to do when the DOT Inspector Arrives at Your Door!

October 29th, 2019 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

Before an inspection, all companies should establish procedures for dealing with visits by a regulatory inspector. These procedures should address a policy on taking pictures and/or recording interviews in the facility as well as security requirements. Inspections are random and unannounced. An important step in the procedure is to establish a primary and alternate contact to be responsible for interacting with any hazardous materials inspector. The primary contact should be aware of all applicable hazardous materials regulations, know where appropriate documents, such as training materials, are stored, and is knowledgeable about the basic requirements of an inspection. Important procedures to have in place include:

  1. Store applicable training certificates/materials in an easily accessible location: Evidence of training is often looked at during an inspection. Make sure that that everyone who signs shipping papers has a corresponding training record.
  2. Store applicable shipping documents in an easily accessible location: Shipping documents are often referenced and analyzed during an inspection. It is important to note that regulatory agencies only require the review of shipping papers from a certain timeframe. Any shipping documents retained beyond that timeframe should be kept in a separate location.
  3. Keep non-dangerous goods shipping documents separate from dangerous goods shipping documents.
  4. Keep any applicable regulatory manuals at the company shipping desk. These manuals should be the most current version of the regulations.
  5. Have a designated location/isle within your facility or warehouse where hazardous materials are stored. Many inspectors will want to look at how hazardous materials are stored, packaged, labeled, marked and otherwise handled prior to transport. Having these materials in a central location helps streamline the inspection process.

When an inspector arrives, it is important that the primary contact stays with the inspector as much as possible throughout the visit. The primary contact should make sure to do the following:

  1. Invite the inspector to a conference room or private office.
  2. Identify the inspector: Ask to see credentials. Write down relevant information.
  3. Determine the scope of the inspection. Ask the inspector what initiated the inspection.
  4. Advise the companies’ legal counsel of the presence of the inspector.
  5. Take notes on what is seen, what is said, by whom, and whether any samples or copies of documents are taken.
  6. When in doubt on any question posed by the inspector, do not answer. Communicate to the inspector that you do not understand the question, and ask the inspector to put the question in writing, addressed to you company counsel or designated contact. Provide them with the companies’ counsel information.
  7. Do not admit to any violation or lack of compliance verbally or in writing. Do not sign anything other than an acknowledgement that the inspector was there.
  8. Prepare a memo as soon as the inspector leaves. It should include all relevant details of the inspection, copies of documents produced or requested, etc.

At the end of the inspection, the officer will give you details regarding the outcome of the inspection and suggestions of how the company can address concerns that were highlighted.
This is normally a very fair process that helps UN shippers comply with regulatory aspects of their shipments.