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In response, PHMSA rescinded its previous interpretations and now says: 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 was recently offered an opportunity to take my training through another company, but I politely declined. I only attend Lion Technology workshops.

Stephanie Gilliam

Material Production/Logistics Manager

Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

The instructor was very very informative, helpful, understandable and pleasant. This course answered many questions I had, being new to this industry.

Frances Mona

Shipping 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

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

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

The instructor made the class very enjoyable and catered to the needs of our group.

Sarah Baker

Planner

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

Kim Graham

Lab Manager

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.