Search

PHMSA Relaxes Position on Hazmat Package Closures and Tape

Posted on 6/8/2018 by Roger Marks

Tape-on-orange.jpgIn May 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a new interpretation of the 49 CFR hazmat rules to clarify the agency’s position on package closures.

In the past, PHMSA has held that “changing the size (e.g., width) of tape from that specified in the packaging test report and closure notification constitutes a change in design.“

Join other hazmat shippers and an expert instructor at the DOT Hazmat Ground Shipper Certification Workshop, coming to Detroit on June 18—19 and Cincinnati on June 19-20,

This meant that if the closure instructions for your package call for a one-inch wide strip of “XYZ tape” to secure the box, and you instead use a two-inch piece of XYZ tape, you’ve will have violated the HMR by using a package of a different “design” to ship your material.  

The consultant who requested clarification from PHMSA argued successfully in his letter that using a wider strip of tape would only improve package performance, provided that the tape was of the same type required in the closure instructions/notification.

In response, PHMSA rescinded its previous interpretations and now says: 

“…increasing the width of the tape from that specified in the packaging test report and closure notification does not constitute a change in design, provided the tape is otherwise of the same specification originally tested.”
tape-Class-9.JPG
Hopefully, this latest PHMSA interpretation will stick. See the PHMSA letter of interpretation here.


Hazardous Materials Shipper Training (49 CFR, IATA, IMDG) 

Meet DOT and IATA training mandates in cities nationwide in 2018. Be confident your shipments are in full compliance with the latest 49 CFR and DGR requirements for ground or air transport, earn CM Points and CEUs, and leave with trusted resources to simplify compliance and support your decisions.
 

Tags: dangerous, goods, hazmat, hazmat shipping, new rules, PHMSA

Find a Post

Compliance Archives

Lion - Quotes

The course was very well structured and covered the material in a clear, concise manner.

Ian Martinez

Hazmat Shipping Professional

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!

Brian Martinez

Warehouse Operator

I will never go anywhere, but to Lion Technology.

Dawn Swofford

EHS Technician

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

Nicole Eby

Environmental Specialist

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

Lion's information is very thorough and accurate. Presenter was very good.

Melissa Little

Regulatory Manager

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory Manager

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

Download Our Latest Whitepaper

Explore ten hazardous waste management errors that caused generators in California the most trouble 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.