The document summarizes key points from a symposium on properly closing steel drums in accordance with regulations for shipping hazardous materials:
1) Shippers are responsible for following closure instructions to ensure drums are properly sealed to prevent leaks during transport.
2) Closure instructions have become more standardized but must match the manufacturer's specifications and be kept up to date.
3) Shippers should check that drums are properly torqued and dimensions meet requirements before shipping, and should contact manufacturers if drums cannot be safely closed or sealed.
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Closure Instructions Labelmaster Sept 2009
1. Closure Instruction Review: Steel Drums Labelmaster Symposium - Chicago September 23-25, 2009 Howard Z. Skolnik Skolnik Industries Inc. - Chicago
2. CFR49, 178.2(c) all shippers of hazardous materials are responsible
4. Hazardous Cargo Bulletin February 2009 Paul Rankin of RIPA asks: do these instructions really help improve safety or are they more likely a source of confusion for shippers?
8. May I have 2 volunteers? I have closed a steel drum I have never closed a steel drum
9. the process that a filler, or re-shipper, must follow torque, dimensional measurements and visual safeguards re-torque before shipment
10. If not properly closed? should be quarantined and the manufacturer contacted for return or replacement
11. No Substitutions!!! If replacement parts are needed get original parts from manufacturer
12. Return Logistics? must convey to their customers the need to present packagings for shipment that are in compliance
13. Retain Testing Certificates ? Though a manufacturer is responsible, its a good idea for the shipper. Outdated and incorrect document retention exposes your company to a probable violation and fine.
14. Now is the time! Review your packaging purchases, Closure Instructions, training and documentation. If a DOT inspector does come to your door, be ready to comply with their requests and demonstrate that you are a compliant shipper.
15. With thanks to Labelmaster! Main Office: 773.735.0700 Direct to Howard: 773.884.1500 Email: howard@skolnik.com