|April 2007 Newsletter
Do you ship dangerous goods in drums?
Our good friend and long time business associate Howard Skolnik of Skolnik Industries in Chicago gave some excellent advice in his current newsletter.
DON'T SHIP A DRUM IF THE CLOSURE IS NOT COMPLETE!
Closure Instructions that are specific for each manufacturer must accompany containers that are DOT certified. These instructions indicate the process that a filler must follow in order to properly close the container in accordance with the Design Qualification Test for that specific drum type. Torque, dimensional measurements and visual safeguards are a part of each closure technique. However, it is the responsibility of the filler not only to follow these instructions, but also to question a container that does not appear to be properly closed. A drum torqued at more or less than the prescribed foot pounds, a ring gap greater than or less than the specified distance, or gaskets which appear not to be properly seated onto the bead, should be quarantined and the manufacturer should be contacted. Just as the DOT expects each filler to close a drum properly, they also expect the filler to respect safe transportation guidelines and question drums that cannot be correctly secured.
Howard Skolnik's website is www.skolnik.com
Transportation Security Administration - important new amendments
TSA issued an interim final rule on March 15, 2007 concerning Security Threat Assessments. The rule changes effective dates for of "submission" of STAs for certain employees rather than "completion" of the STAs, a very significant change.
The requirement for Security Threat Assessment submissions for employees of aircraft operators, foreign air carriers, indirect air carriers and indirect air carrier proprietors, general partners, officers, directors and certain owners has been extended once more to May 15, 2007.
The requirement for Security Threat Assessment submissions for agents of aircraft operators, foreign air carriers and indirect air carriers has been extended to July 15, 2007.
After the above dates the operators may not allow unescorted access to air cargo for any individual unless the operator has submitted the information for that individual to TSA.
It should be noted that there is a significant difference between "submitted" STAs and "completed" STAs.
"Submitted" employees will be permitted to have unescorted access to air cargo while the employer is waiting for TSA to complete the threat assessment.
TSA will advise the dates for completion of the STAs in a future rulemaking.
The Security Threat Assessments are required for employees and agents of aircraft operators, foreign air carriers, indirect air carriers who have unescorted access to air freight from the time the shipment is offered to a carrier or indirect carrier or their agents (subcontractors).
If you are not current with the requirements go to
Type 19515 and the Docket should pop up. Click on "Reverse Order to see the
Next Month - Overpacks