Lion.com will be unavailable for about 30 minutes on Friday, April 25 at 5 PM ET for scheduled site updates.
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

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right.

Gregory Thompson

Environmental, Health & Safety Regional 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

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.

Teresa Arellanes

EHS Manager

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

Lion is my preferred trainer for hazmat and DOT.

Jim Jani

Environmental Coordinator

The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information.

Stephanie Venn

Inventory Control Specialist

Download Our Latest Whitepaper

Get to know the top 5 changes to OSHA’s revised GHS Hazard Communication Standard at 29 CFR 1910.1200 and how the updates impacts employee safety at your facility.

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.