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Closure Instruction Review: Steel Drums Labelmaster Symposium - Chicago September 23-25, 2009 Howard Z. Skolnik Skolnik Industries Inc. - Chicago
CFR49, 178.2(c)  all shippers of hazardous materials are responsible
Closure Instruction & Common Sense  has now become a scientific process
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?
not generic manufacturer specific must be current
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May I have 2 volunteers? I  have closed  a steel drum I  have never  closed a steel drum
the process that a filler, or re-shipper, must follow  torque, dimensional measurements and visual safeguards re-torque before shipment
If not properly closed? should be quarantined and the manufacturer contacted for return or replacement
No Substitutions!!! If replacement parts are needed get original parts from manufacturer
Return Logistics? must convey to their customers the need to present packagings for shipment that are in compliance
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 Outdated and incorrect document retention exposes your company to a probable violation and fine.
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.
With thanks to  Labelmaster! Main Office: 773.735.0700 Direct to Howard: 773.884.1500 Email: howard@skolnik.com

More Related Content

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
  • 3. Closure Instruction & Common Sense has now become a scientific process
  • 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?
  • 5. not generic manufacturer specific must be current
  • 6.
  • 7.
  • 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