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In response, PHMSA rescinded its previous interpretations and now says: 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

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

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

Steven Erlandson

Environmental Coordinator

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

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

I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop.

Tom Bush, Jr.

EHS Manager

The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!

Brian Martinez

Warehouse Operator

Lion is easily and consistently the best option for compliance training. I've learned new information from every instructor I've had.

Rachel Mathis

EHS Specialist

The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information.

Stephanie Venn

Inventory Control Specialist

I can't say enough how pleased I was with this course! Everything finally makes sense.

Kim Graham

Lab Manager

Download Our Latest Whitepaper

Knowing why TSDFs reject loads of hazardous waste—and the exact steps to follow if it happens—can reduce your anxiety and uncertainty about rejection.

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.