By now, most of our Newsletter readers know that for all HazMat packagings, the packaging manufacturer is required by CFR 178.2(c) to deliver Closure Instructions with each package sold. Recently, a customer informed us that one of their other suppliers for a hazmat packaging refused to give them a Closure Instruction and UN Certification, claiming it was “proprietary information.” This is completely untrue and puts a shipper in danger of being non-compliant with DOT! Furthermore, if the shipper chooses to close theirs package without following the specific Closure Instructions from the manufacturer, the shipper would also be liable for a DOT non-compliance violation. Closure Instructions for steel drums require that the closing of a steel drum be translated into a technical instruction. These instructions are written without any DOT guidelines but must indicate the measures necessary in order to properly secure a package for transport. DOT does expect Closure Instructions to include some reference to torque capacities. These measures may include; specially calibrated tools; measurements; torque; and other familiar references. Because UN certified drums in the US must be re-tested annually, be sure that your Steel Drum supplier is providing current Closure Instructions that meet the requirements of CFR 178.2(c), and that you use the tools necessary to comply with these instructions. Some tools may require scheduled recalibrations. Lastly, verify that the Closure Instructions are being followed at each shipping location. Click here to verify that you have current SKOLNIK Closure Instructions for all your SKOLNIK containers.
DOT/UN Safety Skolnik Newsletter