Lion will be closed on Monday, May 25. For online training support, please contact support@lion.com.
Search

PHMSA Package Tape Enforcement Policy Ends August 31

Posted on 8/22/2022 by Roger Marks

PHMSA’s policy of enforcement discretion regarding use of alternate adhesive tape to close UN rated packagings will end on August 31, 2022. 
 
The policy allows shippers who are unable to obtain the exact type of tape required by the manufacturer’s closure instructions to use an alternative tape that will provide an equal level of safety, when certain conditions are met. PHMSA released the policy in May, in response to supply chain disruptions and shortages.
 
Read more: PHMSA Hazmat Enforcement Discretion on Packaging Tape

While the policy of enforcement discretion ends at the end of August, PHMSA recently updated its position on the use of package tape that is not identical to the tape in the UN packaging test report.
 
In a revised letter of interpretation shared by the Council on Safe Transportation of Hazardous Articles (COSTHA), PHMSA states:
 
“a change in tape from the originally tested package to tape with verifiable equal or superior properties (e.g., tensile strength of film or adhesion properties) that will perform the same or better when tested does not constitute a change in design that would require additional design qualification testing.”

In the past, PHMSA had maintained that using any tape other than what the manufacturer’s closure instructions require would constitute a change to package design that would require additional testing.
 
To close a hazmat package using tape other than what’s required by the manufacturer's instructions, the shipper must verify that the tape they use will perform as well or better than what the package manufacturer calls for.

The shipper must be able to prove with available data that the alternative tape will provide an equal or superior level of safety. The shipper must take responsibility if alternate tape is used and the package fails, because the manufacturer’s closure instructions were not followed exactly. 

PHMSA Package Tape Enforcement Policy Ends August 31

Recurrent DOT Hazmat Training Available Online 

Join an expert Lion instructor for a live, one-day webinar to help satisfy DOT’s recurrent hazmat training mandate at 49 CFR 172.704. DOT requires hazmat training once every three years for all “hazmat employees.”

Live webinars blend the convenience of online learning with the reliable, up-to-date training you expect from Lion Technology. Join from anywhere, get answers to your questions, and download robust regulatory resources to support your decision making.
 
Recurrent Hazmat Ground Shipper Certification Webinars
September 26  |  October 18  |  Sign up 

Or train at your own pace with these comprehensive online courses:
Hazmat Ground Shipper Certification (DOT)
Recurrent Hazmat Ground Shipper Certification (DOT)

Tags: hazardous materials, hazmat enforcement, hazmat shipping, PHMSA

Find a Post

Compliance Archives

Lion - Quotes

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

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

Sarah Baker

Planner

The course was very well structured and covered the material in a clear, concise manner.

Ian Martinez

Hazmat Shipping Professional

The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!

Curtis Ahonen

EHS&S Manager

I have been to other training companies, but Lion’s material is much better and easier to understand.

Mark Abell

Regional 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

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

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

Tom Berndt

HSE Coordinator

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

This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.

Quatama Jackson

Waste Management Professional

Download Our Latest Whitepaper

Use this guide to spot which tanks and substances are regulated under EPA's Underground Storage Tank program, and which are excluded as of October 2018.

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.