In 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In response, PHMSA rescinded its previous interpretations and now says: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.”
Hopefully, this latest PHMSA interpretation will stick. See the PHMSA letter of interpretation here.
Meet DOT and IATA training mandates
Hazardous Materials Shipper Training (49 CFR, IATA, IMDG)
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.