Time flies. Can you believe that it has been 20 years since RSPA (now PHMSA) published docket HM-126F regarding training?

Final rule HM-126F is now incorporated into the 49 CFR regulations Part 172 Subpart H. Subpart H stipulates that:

1. A hazmat employer shall ensure that each of its hazmat employees is trained in accordance with the requirements prescribed in this subpart
2. Employees may not perform functions without appropriate training
3. Training may be provided by the hazmat employer or other public or private sources
4. A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the topics covered

Hazmat employee training must include the following:

1. General awareness/familiarization training
2. Function-specific training
3. Safety training
4. Security awareness training
5. In-depth security training

Often times both function-specific and in-depth security training is better done onsite by the employer. It is the employer’s responsibility to certify that the hazmat employee can perform their job, and do so safely.

For more than 25 years, ICC has provided companies with training that complies with these regulations. We offer training that complies with the general awareness/familiarization, security awareness, safety and some function specific topics.

Ask us about our scheduled public training for ground, air or ocean at our facilities across North American. We also offer GHS training, and new OSHA compliant safety training.

Call 888.442.9628 for more information. Have a problem? We have a solution.

UN Packaging codes reveal necessary information about a package’s specifications.  They provide concise answers to questions of:
what it can hold, how much, where it was authorized, when it was made, etc.
The UN packaging code, however, doesn’t always tell the whole story…

Although there may be other test levels achieved, these may not be reflected on the packaging itself.  For example, take a steel drum that has successfully passed the most stringent tests (PG I), and is marked accordingly with the ‘X’ performance level.  This package, in all probability, can/has also passed the less rigorous tests required to meet both the ‘Y’ and ‘Z’ performance level. (Referencing a testing certificate, a test report, or the registration of a successfully tested package, will confirm this.)

So what does this all mean?
Filling limits for single or composite packaging, containing less hazardous material for which they were tested & marked (e.g. PG III material in a PG I packaging), can be re-calculated as per below.

Provided all the performance criteria can still be achieved by the higher relative density product, the following will apply:

For liquids:

a.  A packing group I packaging may be used for a packing group II material with a specific gravity not exceeding the greater of 1.8, or 1.5 times the specific gravity marked on the packaging.

b. A packing group I packaging may be used for a packing group III material with a specific gravity not exceeding the greater of 2.7, or 2.25 times the specific gravity marked on the packaging.

c. A packing group II packaging may be used for a packing group III material with a specific gravity not exceeding the greater of 1.8, or 1.5 times the specific gravity marked on the packaging.

For Solids:

A single or composite packaging which has been tested and marked for liquids may be filled with solids to a gross mass not exceeding the capacity of the packaging in liters, multiplied by the specific gravity indicated in the package marking, or 1.2 if there is no indication in the marking.  In addition,

a.  A single or composite packaging which has been tested and marked for packing group I liquids may be filled with a packing group II solid to a gross mass in kilograms not exceeding the capacity in liters multiplied by 1.5, multiplied by the specific gravity indicated in the package mark (or 1.2 if there is no indication in the marking).

b.  A single or composite packaging which has been tested and marked for packing group I liquids may be filled with a packing group III solid to a gross mass in kilograms not exceeding the capacity in liters multiplied by 2.25, multiplied by the specific gravity indicated in the package mark (or 1.2 if there is no indication in the marking).

c.  A single or composite packaging which has been tested and marked for packing group II liquids may be filled with a packing group III solid to a gross mass in kilograms not exceeding the capacity in liters multiplied by 1.5, multiplied by the specific gravity indicated in the package mark (or 1.2 if there is no indication in the marking).

For more information, please to refer to the applicable regulations:

TDG: CAN/CGSB – 43.150 – 97 – Part II, 13 & 14
49 CFR: Part 173.24 a (b) (1)-(3)
UN Model Regulations (17^th Ed.): Part 6.1.3 – Note 3
ICAO: Part 6, Chapter 2, Note 3
IATA: Section 6.0.4.0.3
IMDG Code: Part 6.1.3, Note 3

UN Performance Packaging	Packaging Chart	Regulations

http://www.thecompliancecenter.com/posters/packaging.htm

http://www.thecompliancecenter.com/regulations/