The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued another final rule on November 7th. Again, this rule making is the only way to amend or change Title 49 for Transportation in the Code of Federal Regulations. In this case, the docket number is HM–219. Its goal is to “to update, clarify, streamline, or provide relief for miscellaneous regulatory requirements”. It has an effective date of December 7, 2018. While the published rule is only 20 pages long there are many areas of revision. Below is a list of the items that jumped out at me while reading it. If you wish to read the full rule making, please visit https://www.phmsa.dot.gov/regulations-fr/rulemaking/2018-23965.
Section 172.205 had changes to paragraph (j) which pertains to the Hazardous waste manifest. You are now allowed to use electronic signatures when completing EPA forms 8700-22 and 8700-22A.
Section 172.407 had revisions to paragraphs (c) and (f). Paragraph (c) now says “inner border approximately 5 mm inside and parallel to the edge”. It still says the inner border must be 2 mm wide and that the thinner line border labels can be used until the end of the year. Paragraph (f) has included some additional references. It now says, “a label conforming to specifications in the UN Recommendations, the ICAO Technical Instructions, the IMDG Code, or the Transport Canada TDG Regulations … may be used in Continue Reading…
Marie-France Dagenais, Director-General of the Dangerous Goods Directorate at Transport Canada told the forum that equivalency certificates will be issued to shippers that apply for them, to allow them to use the new mark. It is expected that an amendment on dangerous goods safety marks will be published in the Canada Gazette, Part I, sometime in June of this year.
When shipping limited quantities (LQ), you do not need to use a UN specification package. But what specs should the package you want to use meet? IATA section 2.7.6 states that the shipper must do a series of drop tests and a 24 hour stacking load test before using the package. Does this then mean that the shipper is done?
Section 184.108.40.206 states that 5.0.2 through 5.0.4 must be met, except for 220.127.116.11, 18.104.22.168, 22.214.171.124(f), 126.96.36.199.(g) and 188.8.131.52.2. Section 5.0.2 is the general packing requirements. The performance test requirements for a package, also known as UN specification packaging, section 184.108.40.206 does not apply as well as 220.127.116.11. After reading these sections, does this mean the shipper can use their package? Not quite, there is another section to read – 18.104.22.168. Here it states that the outer packaging must meet the construction requirements of section 6.2. For combination packages, the most used outer packaging is the fibreboard box. In section 6.2.12, it states that the box must be subjected to the Cobb test. This is a test to determine the water absorbency of the fibreboard box, where the increase in weight cannot exceed 155 g/m2.
Are shippers aware of this requirement? And how are they to determine this when selecting a packaging to use? It might just be easier to use a UN specification package and send the shipment Continue Reading…