OOSC, Part II, Item 3. c. Bulk Packaging Authorization
| Entry Date | October 28, 2017 |
|---|---|
| Issue Number | 17-045-HAZ |
| Name | Kevin Hogan |
| Agency | Michigan State Police |
| Address | 7150 Harris DriveDimondale, Michigan, 48821United StatesMap It (opens in a new tab) |
| Phone | (734)780-6534 |
| Fax | (517) 284-8127 |
| [email protected] | |
| Committee | Hazardous Materials Committee |
| Status | Closed |
| Summary of Issue | Industry representatives reported to the Hazardous Materials committee that some jurisdictions are placing cargo tanks out of service as unauthorized packages based on the fact that the cargo tank tests dates markings show that the tank’s tests have expired. An Ad-hoc committee was developed to research this issue and came up with the following recommendation. |
| Justification or Need | The policy statement found in part III of the Out of Service criteria states that a condition that fails to communicate the hazard or is an imminent hazard would be out of service. A violation of the marking of the test and inspection markings found in 180.415 does not meet the above criteria. In order to achieve the goals of the Commercial Vehicle Safety Alliance the committee proposes the following. |
| Request for Action | Add the following note to part III of the out of service criteria. 3. BULK PACKAGES c. Bulk Package Authorization An out-of-service condition exists when transporting HM/DG in a bulk package not authorized for the material being transported. Unless otherwise indicated herein, specification shortages including expired test dates and markings shall not disqualify an otherwise authorized package. |