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

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

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

Michele Irmen

Sr. Environmental Engineer

The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!

Brian Martinez

Warehouse Operator

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training.

Caroline Froning

Plant Chemist

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

Amazing instructor; real-life examples. Lion training gets better every year!

Frank Papandrea

Environmental 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 training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

Download Our Latest Whitepaper

This guide will help you identify 25 of the most -cited errors in RCRA training, recordkeeping, hazardous waste ID, container management, universal waste, and laboratories.

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.