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In response, PHMSA rescinded its previous interpretations and now says: 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

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!

Oscar Fisher

EHS Manager

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

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

Brittany Holm

Lab Supervisor

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

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

Download Our Latest Whitepaper

Get to know the top 5 changes to OSHA’s revised GHS Hazard Communication Standard at 29 CFR 1910.1200 and how the updates impacts employee safety at your facility.

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.