PHMSA Package Tape Enforcement Policy Ends August 31
The policy allows shippers who are unable to obtain the exact type of tape required by the manufacturer’s closure instructions to use an alternative tape that will provide an equal level of safety, when certain conditions are met. PHMSA released the policy in May, in response to supply chain disruptions and shortages.
Read more: PHMSA Hazmat Enforcement Discretion on Packaging Tape
While the policy of enforcement discretion ends at the end of August, PHMSA recently updated its position on the use of package tape that is not identical to the tape in the UN packaging test report.
In a revised letter of interpretation shared by the Council on Safe Transportation of Hazardous Articles (COSTHA), PHMSA states:
“a change in tape from the originally tested package to tape with verifiable equal or superior properties (e.g., tensile strength of film or adhesion properties) that will perform the same or better when tested does not constitute a change in design that would require additional design qualification testing.”
In the past, PHMSA had maintained that using any tape other than what the manufacturer’s closure instructions require would constitute a change to package design that would require additional testing.
To close a hazmat package using tape other than what’s required by the manufacturer's instructions, the shipper must verify that the tape they use will perform as well or better than what the package manufacturer calls for.
The shipper must be able to prove with available data that the alternative tape will provide an equal or superior level of safety. The shipper must take responsibility if alternate tape is used and the package fails, because the manufacturer’s closure instructions were not followed exactly.
Recurrent DOT Hazmat Training Available Online
Join an expert Lion instructor for a live, one-day webinar to help satisfy DOT’s recurrent hazmat training mandate at 49 CFR 172.704. DOT requires hazmat training once every three years for all “hazmat employees.”
Live webinars blend the convenience of online learning with the reliable, up-to-date training you expect from Lion Technology. Join from anywhere, get answers to your questions, and download robust regulatory resources to support your decision making.
Recurrent Hazmat Ground Shipper Certification Webinars
September 26 | October 18 | Sign up
Or train at your own pace with these comprehensive online courses:
Hazmat Ground Shipper Certification (DOT)
Recurrent Hazmat Ground Shipper Certification (DOT)
Tags: hazardous materials, hazmat enforcement, hazmat shipping, PHMSA
Find a Post
Recent Posts
Compliance Archives
Download Our Latest Whitepaper
Use this guide as a quick reference to the most common HAZWOPER questions, and get course recommendations for managers and personnel who are in need of OSHA-required HAZWOPER training.
By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.