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.
Drum It Up! Steel Drum Industry News, Trends, and Issues
Archive for the ‘Safety’ Category
Recent years in the global metals industry have been challenging. The uncertain economic climate, and slowing demand due to tariffs from key markets such as China, has softened the decade of growth. At the same time, opportunities have emerged for metal producers that have introduced some innovation. One area that is getting attention is the auto industry in which they are “lightweighting” their metals. “Lightweighting” is a term used to refer to metals that provide strength while reducing thickness and weight. In the auto industry, every 100 pounds of steel translates into a fuel economy increase of 1% to 2%. Therefore, some steel drum manufacturing companies are also “lightweighting” their drums in order to reduce costs. However, the drum industry and the auto industry are not alike in their projected goal. While safety is always a concern for an auto manufacturer, fuel economies do much to help sell cars. For steel drums, risk reduction of a packaging is our #1 priority, and the most common failures result from fork-lift punctures and nail punctures. In the US, 90% of steel drum failures are from poor handling. In order to overcome this type of failure, the design of the drum must be sound, especially in details such as steel thickness. Compared to other steel drum manufacturers, Skolnik builds drums that exceed industry standards and as a result, our drums are thicker and heavier. To our customers that ship critical contents, they know that increasing steel thickness reduces the risk of any type of puncture, resulting in the saving of many dollars of clean-up and lost contents expense.
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:
- 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.
- 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).
- 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.
- 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.
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.
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.
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
- 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.