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

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.

Amanda Oswald

Shipping Professional

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

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 was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years!

Tony Petrik

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

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

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

Sarah Baker

Planner

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

I love that the instructor emphasized the thought process behind the regs.

Rebecca Saxena

Corporate Product Stewardship Specialist

Download Our Latest Whitepaper

Use this guide as a quick reference to the most common HAZWOPER questions, and get course recommendations for managers and personnel who are in need of OSHA-required HAZWOPER training.

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.