OOSC, Part III, Item 3. Bulk Packages - Open Manhole Covers on Non-Specification Bulk Packages
| Entry Date | February 14, 2008 |
|---|---|
| Issue Number | 08-011-HAZ |
| Name | R. C. Powell |
| Agency | Virginia State Police |
| Address | 2900 Pruden Blvd.Suffolk, VA, 23434United StatesMap It (opens in a new tab) |
| Phone | (757) 925-2432 |
| Fax | (757) 925-3581 |
| [email protected] | |
| Committee | Hazardous Materials Committee |
| Status | Closed |
| Summary of Issue | This section applies to specification packages, except that items "c." and "e." apply to all packages. d. Venting Devices, Manhole Covers and Discharge Valves Missing or improperly secured manhole covers, venting devices, or discharge valves constitute an Out-of-Service condition. According to this criteria, an open manhole on a non-specification bulk package is not an OOS condition. |
| Justification or Need | Non-specification bulk packages may transport the same materials as specification bulk pacakges in some cases. It should not matter if the package is specification or non-specification if there is an open manhole. |
| Request for Action | Delete "This section applies to specification packages, except that items "c." and "e." apply to all packages." This change would make applicable all items "a." through "f." to both specification and non-specification bulk packages. There should also be discussion for IBCs and portable tanks with open "fill openings". These packages are also bulk packages and should be considered. |