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

I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!

George Chatman

Hazardous Material Pharmacy Technician

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

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

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

Jeremy Bost

Environmental Health & Safety Technician

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!

Henry Watkins

Hazardous Waste Technician

I will never go anywhere, but to Lion Technology.

Dawn Swofford

EHS Technician

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

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

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

Download Our Latest Whitepaper

Look beyond the annual "Top 10 List" to see specifics about the most cited OSHA health & safety Standards and the individual regulations that tripped up employers the most last year. 

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.