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

Archive for the ‘HazMat’ Category

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.

Carriers Fine Shippers for Undeclared Hazardous Cargo

September 24th, 2019 by Howard Skolnik

Filed under: HazMat, Safety, Skolnik Newsletter

A quarter of all liner fires reported to the Cargo Incident Notification System (CINS) relate to mis-declared cargo, particularly hazardous materials. It is an age-old problem that has blighted shipping for too long, rogue shippers willfully breaking the rules to avoid freight rate and insurance premiums on dangerous goods, or committing customs fraud by declaring high value goods as more common items. The invention of the steel container made it even easier to conceal such fraudulent activity, leaving shipping lines with an uphill challenge to combat it.

With the number of container fires rapidly escalating, a few carriers recently announced that they would levy penalties on shippers for mis-declaring cargoes. These fires come at great expense to the carriers and put all on-board cargo at risk, as well as the integrity of the ship. Hapag-Lloyd, which last year shipped nearly half a million dangerous goods, effective September 15, 2019, fine shippers $15,000 for undeclared or mis-declared hazardous cargo. HMM will fine the same amount, while Evergreen announced a penalty of $35,000.

While more carriers are likely to follow the lead, the question of will the threat of financial punishment help to correct the behavior of the less willfully negligent shippers. It is unlikely to change the attitude of any rogue shipper who will still bet on evading the proper shipping regulations. It is hoped that most law-abiding shippers will welcome any measure that will help reduce the risk of their cargo being delayed or destroyed by the irresponsible action of others.

Labelmaster’s DGS draws nearly 300!

September 17th, 2019 by Howard Skolnik

Filed under: HazMat, Industry News, Skolnik Newsletter

Last week (September 4-6, 2019) at the Sheraton Grand in Chicago, Labelmaster’s 14th Annual Dangerous Goods Symposium (DGS) rocked!. Known as the preeminent conference of dangerous goods trainers, shippers, packagers, manufacturers as well as Federal Regulators, the 2019 Symposium broke the attendance record! A gathering of the most prominent industry leaders and presenters provided insights and practical advice to help navigate the most common, and many complex, DG issues. The agenda included a well-rounded list of relevant topics, including:

  • Creating a Culture of Safety
  • Domestic & International Regulatory Updates
  • Virtual Reality in Training
  • Drone Delivery
  • Carrier Variations
  • Lithium Battery Recycling and Regulations

Some of the the speakers and workship leaders included Peter Mackay of Hazardous Cargo Bulletin, Air Canada’s David Bolton, Nick Carlone of Cargo Publications, Mike Hoysler of FedEx, Geoff Leach of The Dangerous Goods Office LTD, Tim Rogers from UPS, Steven Webb of PHMSA and Pete Wagner of Purolator. Most memorable was Vinnie Desiderio from USPS who conducted a live telephone interview with his mother, a typical shipper who would benefit from hazmat training!

The Symposium highlight was a social night of dueling pianos at Howl at the Moon.

Thank you to everyone at Labelmaster for putting forth a tremendous effort to make DGS-14 a valued global event!

New Regulation for Lithium Battery Manufacturers and Distributors

August 3rd, 2019 by Howard Skolnik

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

There is a new requirement for lithium cells and batteries that has the potential of creating a huge wave within the dangerous goods community within the next 2 years. This requirement is known as the “UN 38.3.5 Lithium cell and battery summary” that can be found in the “Recommendations on the Transport of Dangerous Goods Modal Regulations Volume II twentieth revised edition”. In paragraph 38.3.5 it states, “the following test summary shall be made available”. The question becomes “made available to whom”? The intent of the paragraph was meant to mean that the 38.3 test summary be made available by manufacturers and subsequent distributors of lithium cells and batteries to regulatory enforcements officials. The test summary refers to the UN 38.3 testing that is conducted on all new lithium batteries.

The testing on these batteries ensures that batteries are in a condition for transport that ensures that the batteries travel safely through the logistics chain. The testing and subsequent documentation also ensures that counterfeit batteries that have not been tested stay out of the logistics chain. According to 38.3.5 the information that “shall” be provided in the test summary include:

  • Name of cell, battery or product manufacturer, as applicable;
  • Cell, battery or product manufacturers contact information to include address, phone number, email address and website for more information
  • Name of test laboratory to include address, phone number, email address and website for more information
  • A unique test report identification number
  • Date of test report
  • Description of cell or battery to include at a minimum;
    • Lithium ion or lithium metal cell or battery
    • Mass;
    • Watt-hour rating or lithium content
    • Physical description of the cell/battery; and
    • Model numbers
    • List of tests conducted and results (i.e., pass/fail)
  • Reference to the assembled battery or testing requirements, if applicable (i.e. 38.3.3 (f) and 38.3.3 (g));
  • Reference to the revised edition of the Manual of Tests and Criteria used and to amendments thereto, if any; and
  • Signature with name and title of signatory as an indication of the validity of information provided. Lithium Cell and Battery Test Summary Challenge with change.

As with most changes that occur with the regulations, the challenge will be communicating the correct application of this rule to shippers, freight forwarders to ensure that there is an understanding that this document is not necessary for transport. Comprehensive and consistent training is an easy way to ensure that the requirement for this document is understood and implemented correctly. Remember, the document is meant to be made available to enforcement officials that need to refer to it should there be an incident involving a lithium battery shipment.