Search

PHMSA Package Tape Enforcement Policy Ends August 31

Posted on 8/22/2022 by Roger Marks

PHMSA’s policy of enforcement discretion regarding use of alternate adhesive tape to close UN rated packagings will end on August 31, 2022. 
 
The policy allows shippers who are unable to obtain the exact type of tape required by the manufacturer’s closure instructions to use an alternative tape that will provide an equal level of safety, when certain conditions are met. PHMSA released the policy in May, in response to supply chain disruptions and shortages.
 
Read more: PHMSA Hazmat Enforcement Discretion on Packaging Tape

While the policy of enforcement discretion ends at the end of August, PHMSA recently updated its position on the use of package tape that is not identical to the tape in the UN packaging test report.
 
In a revised letter of interpretation shared by the Council on Safe Transportation of Hazardous Articles (COSTHA), PHMSA states:
 
“a change in tape from the originally tested package to tape with verifiable equal or superior properties (e.g., tensile strength of film or adhesion properties) that will perform the same or better when tested does not constitute a change in design that would require additional design qualification testing.”

In the past, PHMSA had maintained that using any tape other than what the manufacturer’s closure instructions require would constitute a change to package design that would require additional testing.
 
To close a hazmat package using tape other than what’s required by the manufacturer's instructions, the shipper must verify that the tape they use will perform as well or better than what the package manufacturer calls for.

The shipper must be able to prove with available data that the alternative tape will provide an equal or superior level of safety. The shipper must take responsibility if alternate tape is used and the package fails, because the manufacturer’s closure instructions were not followed exactly. 

PHMSA Package Tape Enforcement Policy Ends August 31

Recurrent DOT Hazmat Training Available Online 

Join an expert Lion instructor for a live, one-day webinar to help satisfy DOT’s recurrent hazmat training mandate at 49 CFR 172.704. DOT requires hazmat training once every three years for all “hazmat employees.”

Live webinars blend the convenience of online learning with the reliable, up-to-date training you expect from Lion Technology. Join from anywhere, get answers to your questions, and download robust regulatory resources to support your decision making.
 
Recurrent Hazmat Ground Shipper Certification Webinars
September 26  |  October 18  |  Sign up 

Or train at your own pace with these comprehensive online courses:
Hazmat Ground Shipper Certification (DOT)
Recurrent Hazmat Ground Shipper Certification (DOT)

Tags: hazardous materials, hazmat enforcement, hazmat shipping, PHMSA

Find a Post

Compliance Archives

Lion - Quotes

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

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

Henry Watkins

Hazardous Waste Technician

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

Nicole Eby

Environmental Specialist

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

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly.

Brittany Holm

Lab Supervisor

The online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

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

Teresa Arellanes

EHS Manager

I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective.

John Gratacos

Logistics Manager

Download Our Latest Whitepaper

Spot and correct 4 of the most common universal waste errors before they result in a notice of violation during a Federal or state inspection.

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.