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Dangerous Goods Instructors Symposium 2013

Dangerous Goods Instructors Symposium 2013. 50 Shades of UN Packaging Paul Rankin Reusable Industrial Packaging Association Howard Skolnik Skolnik Industries , Inc. 50 Shades of UN Packaging.

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Dangerous Goods Instructors Symposium 2013

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  1. Dangerous Goods Instructors Symposium 2013 50 Shades of UN Packaging Paul Rankin Reusable Industrial Packaging Association Howard Skolnik Skolnik Industries, Inc.

  2. 50 Shades of UN Packaging • An insightful examination of the tangled relationship between dangerous goods regulations and compliant packaging.

  3. DGIS 2013 • RIPA Reusable Industrial Packaging Association Washington, DC • Skolnik Industries Industrial Packaging for Critical Contents Chicago, IL

  4. From unregulated DG movements to Spec Packaging to POPS1905 – BOE – ICC – DOT – RSPA/PHMSA

  5. A Brief History of HazMat Regulation in the U.S. From Specification Packaging to Performance Oriented Packaging

  6. Hazardous materials packagings have been regulated in the U.S. by both governmental and private organizations since the early 1900s. • First by the Bureau of Explosives (BOE); later by the Interstate Commerce Commission; then DOT (1967)

  7. In 1974, the Hazardous Materials Transportation Act consolidated all DOT regulatory authority in the Materials Transportation Bureau. In 1977 RSPA was formed. Today, hazmat regulations are controlled by PHMSAs Office of HazMat Safety

  8. BOE and ICC loosely regulated hazmat packaging (avoid leakage). By 1967, regulatory controls over packaging expanded and “specification” packaging was created.

  9. Specification packaging was rigid and, at times, almost funny. DOT 15 box (group 2 hazmats)only made from: Southern yellow pine Hemlock NC pine Douglas Fir Larch

  10. Spec packaging testing rules were rather stringent: Tests 3 times per year Test samples retained (one year) Drop (4 ft.) Hydro (20 p.s.i. for 5 minutes) Leakproofness (15 p.s.i. water or soap over seams)

  11. Closure requirements existed, but only for shippers. Sample closure requirement (1985) 178.116-8 Closures (a) Adequate to prevent leakage; gaskets required. (b) Closing part (plug, cap, plate, etc.,) must be made of metal as thick as prescribed for head of container….

  12. December 1990. At that point, the packaging world as we knew it was turned on its head

  13. Test Criteria CFR49, Part 171.1 Applicability of Hazardous Material Regulations (HMR) to persons and functions.

  14. Federal hazardous materials transportation law directs the Secretary of Transportation to establish regulations for the safe and secure transportation of hazardous materials in commerce…

  15. The Secretary is authorized to apply these regulations to persons who transport hazardous materials in commerce….to persons who cause hazardous materials to be transported in commerce...

  16. …and to persons who manufacture or maintain packaging of a component of packaging that is represented, marked, certified or sold as qualified for use in transportation of hazardous material in commerce.

  17. Who is Regulated? • HM Producers • HM Packaging Manufacturers • HM Shippers • Anyone who may participate in other related transport over public right-of-way.

  18. What is regulated? • Steel Drums • Plastic Drums • IBC’s • Pails • All packagings designed to transport HM

  19. Regulating Agencies • National Governments (e.g. DOT; TDG) • United Nations (Global Recommendations) • IATA and ICAO (air) • IMDG (Water) • RID (Rail) • ADR ( Road)

  20. United Nations Testing US DOT Acting Competent Authority

  21. Performing UN Testing • Skolnik manufactures about 150 different packagings that are UN certified. • DOT requires packaging designs to be recertified every 12 months. • Skolnik is a self certifier and does its own testing.

  22. Over to Skolnik….. • Taking you into our Test Lab and focusing on set up and performance of an individual UN Design Type Test.

  23. Introduction to Testing

  24. Tools and Equipment

  25. Bead and Chime

  26. Adding Weightfor the Solid Drop Test

  27. Open Head Closure Ring

  28. Open Head Stack Test

  29. Open Head Hydrostatic Test

  30. Open Head Drop Test

  31. Open Head Leakproof Test

  32. Pass! All test criteria have been met successfully.

  33. Inconsistencies • LOGSA at Tobyhanna • Policing Actions

  34. LOGSA Huge percentage of failures for all packaging design types No failure analysis No subsequent action (except a few fines) Publish results on web; no explanation Alternative Design Validation Testing – not useful Does not reflect field performance

  35. What’s Ahead….. • Tobyhanna moved from policing to research • Tobyhanna test results available on line at DOT.gov

  36. Knock Knock….. What to do when the DOT calls! • Always anticipate an inspection • Run a self audit once per quarter • Keep copies of all necessary DOT records (e.g. employee training) in one location. Be sure another person knows where the records are kept.

  37. 4. Be sure employees can answer basic questions DOT might ask (e.g. have you been trained in this job function). 5. Accompany the DOT inspector as he conducts the inspection. Record key actions on paper. 6. Get the inspectors name.

  38. 7. Keep exit briefing form(s). 8. Fix all noted problems. 9. Call your lawyer.

  39. DGISROCKS! Thank you! Did you learn something new? Questions? Comments? Stories to share?

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