But Don’t Lose Hope…
As many of you know, back in May, the Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Notice of Enforcement Discretion addressing the lack of availability of certain types of tapes required for shipping. In that notice, PHMSA allowed shippers to use alternate tapes so long as they met certain criteria. It also stated that the enforcement discretion would last until August 31, 2022.
Fear not all of you who are still struggling to find the exact tapes required by manufacturer’s closure instructions. In a revised letter of interpretation (LOI) disseminated by the Council on Safe Transportation of Hazardous Articles, PHMSA asserts:
“that a change in tape from the originally tested package to tape with verifiable equal or superior properties (e.g., tensile strength of film or adhesion properties) that will perform the same or better when tested does not constitute a change in design that would require additional design qualification testing.”
PHMSA also continues its assertion that certain “performance data” indicating different types of tapes will perform in the same manner as the originally tested tape does not require additional design qualification testing as well.
“Consistent with our revised response to Q1, our response is revised to state that if there is data available showing that a different tape with equal or superior properties (e.g., tensile strength of film or adhesion properties) will perform the same or better than the tape used in testing the original packaging, this information could be used to permit the use of the different tape without having to perform additional design qualification testing.”
Although the struggle remains “real,” and tape is still hard to find, at least PHMSA for the time being understands and is allowing alternative measures to help alleviate shipper’s pains. And speaking of pains, if you prefer short articles that give you the meat and potatoes quickly and plainly, make sure to follow us on Facebook, Twitter, and LinkedIn to be the first to know when we drop new content like this. You can also, opt-in to our newsletter for exclusive offers, regulation changes, and industry news!
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