New Packaging Regulations Affect Hazmat Shippers

We might have to look hard to find an area of packaging operations that has had less training emphasis than closure and closure verification.

MEETING the challenges of today's packaging regulations can be difficult and time consuming for shippers. And it keeps getting tougher to stay current with packaging regulations. New federal regulations are affecting domestic and international shippers of hazardous materials, and then there is the continued turnover in shipper personnel in today's job market, which creates a never-ending demand for knowledge training and a constant drain on company resources, just to keep up and stay current.

These issues and more seem to lead to confusion on the part of shippers everywhere about what types of containers are appropriate for use with hazardous materials, how to verify the selected container is acceptable for use with a particular waste stream, and so on.

For example, something as simple as container closure procedures can turn into a major headache without the proper information. Container closure instructions are not generic, and while at first it may seem a simple matter of common sense on how to close a package, there is more to it than meets the eye.

Container closure is particularly important to public safety and especially for all those involved in the transport, handling, and disposal or reclamation of hazardous materials. Effective and complete container closure in accordance with package qualification is critical to preventing leakage of hazardous materials in transport. The U.S. Department of Transportation considers container closure so critical to transport safety that it has made the topic an important part of the newly reformatted and enhanced U.S. DOT regulations. These enhancements, which became effective on Oct. 1, 2004, make all shippers of hazardous materials responsible for strictly following the manufacturer's closure instructions that accompany all DOT and UN marked packagings (reference Title 49, Code of Federal Regulations, Section 178.2c).

Significantly, shippers are required under the regulations to assure that proper closure procedures have been followed. DOT even goes one step further by suggesting that shippers incorporate verification of container closure in their operating procedures prior to offering closed containers for shipment.

All of us probably could agree that training, good procedures, and follow-up are essential to success in any situation, but we might have to look hard to find an area of packaging operations that has had less training emphasis than closure and closure verification as a feature of health, safety, and security responsibilities. Understandably, there are many potential interpretations of these new requirements, but the one sure and certain way that exists for shippers to virtually guarantee their compliance, to reduce potentially dangerous transport conditions, and to reduce potential liability is to obtain, maintain, and make it everyone's responsibility to follow the manufacturer's closure instructions for each package or packaging in use.

Salvage Drums: Much More than Trash Cans
How do closure instructions really affect hazardous material shipment? Take Salvage Drums as an example. Salvage Drums are probably the most recognized specialty container in the hazardous material shipping arena. But do the shipper's personnel really understand what Salvage Drums are and how to properly use and close them?

It's their business to understand, because the shipper is legally responsible and liable for ensuring all packages offered for transport are selected, used, labeled, and closed in accordance with all of the applicable regulations. Following manufacturer's closure instructions is vitally important to package performance and transport safety in critical hazardous material shipments.

The ease of use of a particular closure may make one packaging more desirable to a shipper than another. For instance, a screw-top Salvage Drum that requires no special tools to close may be better suited for a shipper's operations because of the personnel costs and time savings when compared to a similar container with another type of closure, such as a bolt-ring. Without proper closure, however, the shipper may be offering hazardous materials that can leak in transport and cause further contamination and damage. Not the least of our collective concerns, of course, is the risk to human life.

Salvage Drums may be best understood by what they are not. For example, despite their looks and our tendency to think of them as such, Salvage Drums aren't simply just oversized trash cans. Salvage Drums are actually specialized containers engineered, designed, manufactured, and tested specifically for transport of dangerous goods that are either damaged, leaking, or have spilled. The closures have been designed for just such purposes and to provide safety and security in transport of hazardous materials. Salvage Drums, like many other types of containers, will have a UN number embossed on them and perhaps even applied to their product label. Again, this in and of itself is not unusual and applies to many other types of containers. The presence of a UN mark does not guarantee that any package with such a mark meets the necessary requirements of a Salvage Drum. These requirements are clearly and concisely spelled out in federal and international regulations (reference 49 CFR 173.3c).

Salvage Drums, for example, are required to have the words "Salvage" or "Salvage Drum" embossed on them and/or applied by the manufacturer on a label. Only by following the proper instructions for container closure can the shipper be certain the packages being offered for transport are actually closed in conformance with all performance objectives for the container. Does your packaging have these markings and important statements present when delivered by the manufacturer or your local supplier? Can you verify package closure, visually or otherwise?

Salvage Drum status and performance is contingent upon being able to successfully close the packaging. This is verified and certified to the shipper and to the public authorities such as U.S. DOT through a Packaging Qualification Notice prepared by each manufacturer of Salvage Drums and updated periodically.

This qualification document should be on file and up to date at each shipper's location where Salvage Drums are offered for transport. Does your packaging have a Qualification Notice? Salvage Drum operation and closure is conveyed to the shipper once again through a written set of closure instructions. These may include diagram(s) and recommended tools that are helpful in accomplishing the task of completing and verifying container closure. Some packagings need no special tools other than a 2x4 or a shovel handle.

The Closure Instructions for a packaging are prepared by each package manufacturer and should be included with each delivery of packagings. Does your packaging have a set of Closure Instructions to allow the user to comply with U.S. and international packaging regulations and requirements?

Avoiding Costly Misapplications
Shippers should make it a priority to be always up to date on packaging regulations and package documentation. This helps the shipper to avoid costly and potentially dangerous misapplication of packagings. Shippers should insist on maintaining current manufacturer data, certifications, and instructions for all packagings from outside suppliers of hazardous material containers, such as Salvage Drums.

For more information about packagings for hazardous material applications, contact the U.S. Department of Transportation or your local supplier or the manufacturer of hazardous material packagings used in your operations. Shippers can avoid possible penalty assessments for non-conforming shipments through closure verification.

Be safe. Follow all package closure and use instructions as well as all state, federal, and international regulations and requirements. Good shipping!

This article appeared in the January 2005 issue of Occupational Health & Safety.

This article originally appeared in the January 2005 issue of Occupational Health & Safety.

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