Archive for the ‘Haz Mat’ Category

Hazmat Paperwork Lifecycle

January 26, 2016

Tim asks,

How long do we need to keep our paperwork for boxes where we print the UN hazmat logo’s on?

I reached out to Lonnie Jaycox (lonnie@jaycoxconsulting.com) for some help on this topic. Below is Lonnie’s reply. Thank you Lonnie for your assistance.

— Ralph

If the Hazmat logo is the certification mark for specification packaging; it depends on the paperwork “who” (which person) the box plant is listed in the regulations.

If the box plant is both the fabricator of the box and the “manufacturer” of the packaging under 49 CFR (It is their name or symbol that appears in the certification string.). Then they will need to keep design qualification test reports for the period specified in 49 CFR 178.601(I) [see below]:

  • Record retention: Following each Design Qualification (DQ) test and each periodic retest on a packaging, a test report must be prepared. The test report must be maintained at each location where the packaging is manufactured, certified, and a design qualification test or periodic retest is conducted as follows:

 

Responsible Party Duration
Person manufacturing the packaging As long as manufactured and two years thereafter.
Person performing design testing Design test maintained for a single or composite packaging for six years after the test is successfully performed and for a combination packaging or packaging intended for infectious substances for seven years after the test is successfully performed.
Person performing periodic retesting

Performance test maintained for a single or composite packaging for one year after the test is successfully performed and for a combination packaging or packaging intended for infectious substances for two years after the test is successfully performed.

If the box plant is a fabricator (not the manufacturer), then is no need for them to retain a copy of the DQ report at all, since there is no requirement that they have it to begin with. In that case, the manufacturer simply gives the construction specification to the box plant to manufacture. However, because the person responsible for the specification and performance of the packaging is required to maintain records for two years after a packaging is no longer manufactured, I would recommend that the production records for boxes marked with a UN specification marking should be retained for two years. That way if there is any question as to the construction of the packaging, the fabricator could demonstrate from their records that the manufacturer’s specifications were followed.

If the “paperwork” mentioned above is not associated with the UN specification marking, I would need some clarification of what UN marking is being discussed.

 

Global Harmonization System Is Here

May 26, 2015

On June 1, 2015 the new International standard updates some OSHA UN HazMat labeling requirements. On this date every MSDS that you have will become outdated and needs to be replace with the Safety Data Sheets format as described by the GHS. You might, if you are not there already done so, begin to gather sheets from your containerboard supplies about the human health risk of “dust” or cellulose fibre. While there is a renewed concern and period of public and expert comment period of the combusted dust issue in “confined” spaces by OSHA and the National Fire Protection Association, the human health assessment is another initiative.

Also the labeling of corrugated and the shippers placards for hazardous materials has changed. Below is a web link to a white paper on the subject. Click here to download White Paper. We have many network contacts in the Chemical Packaging Committee of Institute of Packaging Professionals to come alongside you. Lonnie Jaycox is one of those people.

Be Prepared: Changing Shipping Regulations

March 3, 2015

AICC just returned from attending the winter meeting of the Chemical Packaging Committee of the Institute of Packaging Professionals. This committee is the one that monitors the global changes in hazardous material packaging and shipping regulations and acts as this Association’s major advocate with the US Department of Transportation. As new members of this committee, this was only AICC’s second time to engage with these experts. What keeps showing up on top of the agenda is the Global Harmonizing System. This is where the US will comply with the UN on the import and export packaging and labeling of hazardous materials.

So how does this impact a corrugated company? One is that the labeling and placards are changing and will need to comply with these global and now domestic requirements by December 31, 2016. The other is that a product that may not have been considered a hazardous material in the past may now be reclassified as a dangerous good. Add to this the changing requirements for food safety thru the Global Food Safety Initiative and all will be busy trying to stay ahead of customers’ needs. This latter issue may have a greater impact on folding carton and rigid box manufacturers.

The entire distribution environment and transportation modes have changed and are changing. So what’s happening with the aging stock of over the road truck drivers? These 55 plus year old men and women are not being replaced by younger drivers who are willing to accept $55-60,000 a year in earnings. This mode will probably seek higher freight rates to attack younger operators. Add to this that US ocean ports are not able to handle the newest and biggest ships. Then compound this with the evolving growth of the small parcel and e commerce shipping modes and a packing company going forward must be nimble to adjust. Maybe more reshoring will occur.

Another issue discussed by those who must handle explosive materials is the need for grounding in manufacturing processes that create static buildup to the extent that a spark can occur. While we do create negative charges in our industries, they are easily dissipated and are generally not an issue. However with OSHA moving in the direction of more dust containment regulations, grounding may move up the scale in importance.

Stay tuned.

UN HazMat Packaging – 49 CFR parts 171-180

January 4, 2012

49 CFR parts 171-180

If you are involved in UN HazMat Packaging you are no stranger to this Code of Federal Regulations Title 49 Transportation. There are upcoming changes to Commodity ORM-D and Limited Quantity markings. These go into effect on January 1, 2013 so there is a year to obtain new printing plates for your operations. The DOT is moving from a rectangular stamp to one that is a diamond shape. This is explained in detail in the Federal Register.Vol.76, No. 12/Wednesday, January 12, 2011/Rules and Regulations on page 3366, yes page 3366. This is described under paragraph 172.315. Whatever happened to the Paper Reduction Act? And don’t forget the training that you must have ever three years.

Our thanks go out to Ten-E for guiding us in this effort.