Search

PHMSA Answers Hazmat Package Test Questions

Posted on 10/20/2017 by Roger Marks

Class_7_Radioactive_Geiger_Counter.jpgIn the sole letter of interpretation posted to PHMSA’s website last month, the administration answered four questions about hazmat packaging requirements for radioactive materials from the Packaging Management Council.

The first question concerns the packaging testing requirements at 49 CFR 173.15(a)(1)(i), which requires offerors of Type A packagings to document information about how, when, where, and by who the packaging was tested. PHMSA makes it clear that—even when the supporting documentation cannot be obtained—a “good faith effort” to obtain the documents is not enough to ensure compliance with the Hazardous Materials Regulations (HMR).

Instead, Type A packaging offerors should use the non-test methods outlined in 49 CFR 173.461 to demonstrate compliance.

The packaging testing documentation rules were bolstered under DOT rulemaking HM 250, finalized in 2011, which amended the rules for Class 7 (radioactive) materials to harmonize with international requirements created by the International Atomic Energy Agency (IAEA).

The updated documentation requirements apply to all Type A packagings offered for shipment after January 1, 2017. 

The letter of interpretation also clarifies the scope and applicability of the HM 250 rulemaking.

Read the full letter on PHMSA’s website.

Final Hazmat Training Workshops of 2017

Meet DOT, IATA, and IMDG hazmat training mandates when Lion presents the final Multimodal Hazmat Shipper Certification workshops of 2017. You will learn a step-by-step approach to properly prepare hazmat shipments in full compliance with 49 CFR, the IATA DGR (air), and the IMDG Code (vessel).

Detroit Oct. 30–Nov. 2 
Cincinnati Oct. 30–Nov. 2
Pittsburgh Dec. 4–7 
Chicago Dec. 11–14

 
 

Tags: DOT, hazmat shipping, Letters of interpretation, PHMSA, radioactives

Find a Post

Compliance Archives

Lion - Quotes

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

More thorough than a class I attended last year through another company.

Troy Yonkers

HSES Representative

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

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

I chose Lion's online webinar because it is simple, effective, and easily accessible.

Jeremy Bost

Environmental Health & Safety Technician

These are the best classes I attend each year. I always take something away and implement improvements at my sites.

Kim Racine

EH&S Manager

The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete.

Felicia Rutledge

Hazmat Shipping Professional

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

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

Download Our Latest Whitepaper

Find out what makes DOT hazmat training mandatory for employees who sign the hazardous waste manifest, a “dually regulated” document for tracking shipments.

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.