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

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

Michele Irmen

Sr. Environmental Engineer

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

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

I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down.

Nicole Eby

Environmental Specialist

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

I chose Lion's online webinar because it is simple, effective, and easily accessible.

Jeremy Bost

Environmental Health & Safety Technician

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

Gregory Thompson

Environmental, Health & Safety Regional Manager

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

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.