Recently, Marc Nichols, Acting Director of Field Services, Eastern Region, of DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) explained to a gathering of hazardous materials professionals the importance of attention to details in the US-DOT Closure Instruction requirement (CFR 172.2(c)).
One example of how details can trip up manufacturers and shippers is that during facility inspections DOT inspectors examine the scheduled calibration of torque tools used to close the drums. Another critical aspect is that Closure Instructions aren’t generic; they’re specific to each drum manufacturer, and in some cases, to a particular model of drum. Therefore, packaging from different manufacturers, even if similar, must be closed in accordance with the Closure/Closing Instructions from each specific manufacturer.
All this means is that shippers must make sure they have current closing instructions from all of their suppliers of DOT-specification packaging, that they are exactly following the appropriate instructions for the specific package or drum they are closing, and that the tools they use for closing have documented torque calibration.
Shippers and transporters should be aware that non-compliance with the Closure Instructions can result in significant fines. For guidance on selecting and properly closing packaging for Hazardous Materials visit www.bascousa.com, or call BASCO at 1-800-776-3786.
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