PHMSA Responds to JHMT Questions Relative to CLOSURE INSTRUCTIONS for Hazardous Materials Packages

摘要

Regulatory requirements for manufacturers' notification to customers regarding closure instructions have been significantly enhanced in recent years. Prior to the issuance of the HM-181 Performance Oriented Packaging rules, manufacturers were told they "should inform" their customers of "any specification requirements which have not been met at time of transfer". With implementation of the HM -181 performance packaging requirements, manufacturers and subsequent distributors were required (by § 178.2) to notify in writing each person to whom a packaging is transferred of all requirements of Part 178 not met at time of transfer and of the type and dimensions of closures needed to satisfy performance test requirements, and shippers were required (§ 173.22) "to perform all functions necessary to bring that package into compliance with Part 178 of this subchapter, as identified by the packaging manufacturer or subsequent distributor."