Search

PHMSA Relaxes Position on Hazmat Package Closures and Tape

Posted on 6/8/2018 by Roger Marks

Tape-on-orange.jpgIn May 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a new interpretation of the 49 CFR hazmat rules to clarify the agency’s position on package closures.

In the past, PHMSA has held that “changing the size (e.g., width) of tape from that specified in the packaging test report and closure notification constitutes a change in design.“

Join other hazmat shippers and an expert instructor at the DOT Hazmat Ground Shipper Certification Workshop, coming to Detroit on June 18—19 and Cincinnati on June 19-20,

This meant that if the closure instructions for your package call for a one-inch wide strip of “XYZ tape” to secure the box, and you instead use a two-inch piece of XYZ tape, you’ve will have violated the HMR by using a package of a different “design” to ship your material.  

The consultant who requested clarification from PHMSA argued successfully in his letter that using a wider strip of tape would only improve package performance, provided that the tape was of the same type required in the closure instructions/notification.

In response, PHMSA rescinded its previous interpretations and now says: 

“…increasing the width of the tape from that specified in the packaging test report and closure notification does not constitute a change in design, provided the tape is otherwise of the same specification originally tested.”
tape-Class-9.JPG
Hopefully, this latest PHMSA interpretation will stick. See the PHMSA letter of interpretation here.


Hazardous Materials Shipper Training (49 CFR, IATA, IMDG) 

Meet DOT and IATA training mandates in cities nationwide in 2018. Be confident your shipments are in full compliance with the latest 49 CFR and DGR requirements for ground or air transport, earn CM Points and CEUs, and leave with trusted resources to simplify compliance and support your decisions.
 

Tags: dangerous, goods, hazmat, hazmat shipping, new rules, PHMSA

Find a Post

Compliance Archives

Lion - Quotes

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow.

Steven Erlandson

Environmental Coordinator

The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly.

Brittany Holm

Lab Supervisor

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well.

Marty Brownfield

Hazardous Waste Professional

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.

Jeffrey Tierno

Hazmat Shipping Professional

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

Download Our Latest Whitepaper

This report details major changes for hazardous waste generators from US EPA’s Generator Improvements Rule, as well as the latest updates from states that are still working to adopt new, stricter Federal requirements.

Latest Whitepaper

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.