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'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

I will never go anywhere, but to Lion Technology.

Dawn Swofford

EHS Technician

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

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

Michele Irmen

Sr. Environmental Engineer

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

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

Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!

Paul Harbison

Hazardous Waste Professional

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

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.