(explosives) except Division 1.4; and 126 – Segregation es? Cargoes may be “rolled” to the next voyage because same as for Class 9, miscellaneous hazardous materials. an appropriate stowage location is not available, or the To the shipper, this may not mean much; however, to the steamship line might assess a surcharge for preferred stow- vessel planner and steamship line, the simple change from age locations onboard the vessel. “48 - stow ‘away from’ sources of heat” to “25 - protected With respect to the new marking requirements, the pro- from sources of heat,” will have more serious implications. posed changes might have a greater impact. Although the Protected from sources of heat is defined as “…packages dimensional requirements would be consistent with in- and cargo transport units must be stowed at least 2.4 m ternational standards and existing U.S. rules that govern (8 feet) from heated ship structures, where the surface the size of UN specification packaging markings, this new temperature is liable to exceed 131 °F (55 °C).” rule, if adopted, may require you to remark inventories Examples of heated structures are steam pipes, heating of your products (assuming that they are not circulated coils, top or side walls of heated fuel and cargo tanks, and out of inventory before the effective compliance date). bulkheads of machinery spaces. In addition, packages This may also require new packaging design and printing. not loaded inside a cargo transport unit and stowed on Although the DOT will most probably provide a generous deck must be shaded from direct sunlight. The surface phase-in period, it is safe to assume that international of a cargo transport unit can heat rapidly when in direct regulatory agencies will not be as lenient. Therefore, you sunlight and in nearly windless conditions, and the cargo should consider a detailed review of existing transpor- may also become heated. Depending on the nature of the tation case markings now and take this proposed rule cargo, and the vessel’s routing, precautions must be taken into account when developing new transport packaging to ensure that exposure to direct sunlight is reduced. markings. To download a copy of the Notice of Proposed Rulemak- ing, visit http://www.gpo.gov/fdsys/pkg/FR-2012-08-15/ Additional Considerations pdf/2012-18431.pdf. PHMSA’s HM-215 rulemaking series Companies should consider negotiating with their is published biannually to ensure that the HMR are con- freight forwarders and steamship lines to ensure that their sistent with international standards and regulations. cargoes will be given preferential treatment and that any stowage surcharges, if applied, will be minimal or non- How Will these Proposed Rules existent. Affect Your Company? Companies should also consider taking into account Practically speaking, the new vessel stowage restrictions other new marking requirements, such as Globally will limit the number of available slots onboard container Harmonized System (GHS), during this packaging review. ships where these goods may be stowed. The consequenc- Companies are also encouraged to establish and follow an annual package, product labeling and Safety Data Sheet review process to ensure that all applicable regulatory requirements are complied with. Steve Hunt is President of ShipMate, Inc., an interna- tionally recognized dangerous goods training and consult- ing firm. Prior to starting ShipMate, Inc., he was the Chief of the Port Facilities & Container Inspection Divisions for the U.S. Coast Guard’s Marine Safety Office in Los Angeles-Long Beach. He helped write many of the current rules for the transport of dangerous goods, including HM- 181 and HM-126F. Hunt is currently developing a series of online training courses through ShipMateUniversity. com and HazMatU.org. For more info: +1 (310) 370-3600, steve@shipmate.com. November 2012 Spray 37
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