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November/December 2019


In November, the Plastic Drum Institute (PDI) unveiled Plastic Drums 101, a technical webinar that provides viewers with a high-level understanding of this critical industrial packaging option.  The 45-slide presentation discusses the unique components of plastic drums, including the difference between open-head and a tight-head drums, as well as how they’re manufactured.  Viewers will learn about permeation and the U.S. Department of Transportation’s compatibility test that helps shippers determine the compatibility and permeation rate of their products. They will also gain knowledge on how to interpret the UN marking on every plastic drum and learn about the performance standards behind them. The webinar is available within the Resources section of and on PDI’s YouTube page.

The Industrial Steel Drum Institute (ISDI) has unveiled Steel Drums 101, a technical webinar that provides viewers with a high-level understanding of this critical industrial packaging option. The 50-slide presentation discusses the unique components of steel drums, including the difference between open-head and a tight-head drums, that make them so versatile, sustainable and safe. Viewers will learn how these drums are manufactured, painted and lined to properly transport and store the materials they may contain.The webinar is available within the Resources section of and on ISDI’s YouTube page. Click here to view the webinar.

The Industrial Packaging Alliance of North America submitted a comment letter to Bill Schoonover, Associate Administrator, PHMSA, regarding a petition for rulemaking P-1720.  The petition P-1720 was submitted by Hazmat Safety Consulting, LLC. The petitioner requests that the restrictions on the use of the “USA” mark be eased to allow foreign made packagings tested by third party labs to carry the USA mark. Currently, under the DOT hazardous materials regulations, the “USA” mark is restricted to packagings manufactured in the U.S.   The application of the “USA” mark has been restricted in this manner since the issuance of HM-181 implementing UN performance packagings in 1990.    IPANA goes on to state  that we are unaware of any changes that support reconsideration of this rationale. IPANA also noted their concern that the proposed change would competitively disadvantage U.S. manufacturers of “USA” marked UN packagings in comparison to manufacturers outside the U.S.  Manufacturers in the U.S. are subject to intense scrutiny by the PHMSA enforcement staff and single packagings are subject to annual periodic retesting.  You can view the petition by clicking here and IPANA’s comments by clicking here.

The Industrial Steel Drum Institute’s Chairman Kyle Stavig and Secretariat Susan Nauman recently traveled to Hawaii to participate in the International Confederation of Drum Manufacturers (ICDM)  Board meeting.  ISDI Chairman Kyle Stavig is also the current Chairman of the ICDM. Many important matters were discussed included annual production statistics for each region as well as promotional efforts regarding steel drums.  A full report on the proceedings will be given at the upcoming Spring IPANA meeting in Pinehurst, North Carolina. Other associations represented include the Asia Oceanic Steel Drum Association (AOSD) and the European Association of Steel Drum Manufacturers (SEFA).

Mr. Kyle Stavig participated in the opening ceremonies at the 5th Asia- Oceanic Drum Association (AOSD) conference in Suzhou, China.  Mr. Stavig also gave a full report on ISDI and ICDM activities. The conference is growing in attendance and scope with over 300 registered guests traveling as far as from Brazil. The scope of the conference was “ Environmental Protection and Social Responsibility”.  A full report will be given at the upcoming ISDI meeting in Pinehurst, North Carolina.  The AOSD conference is held every three years with the next conference location in Korea.

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Regulatory Updates

As part of the Trump Administration’s continuing deregulatory efforts, on October 9, 2019, President Trump issued two executive orders, designated EO 18391 and EO 13892, with an aim to further restrict the use of agency guidance documents. The first EO, #13891 sets forth new requirements for the issuance, rescission, and transparency of agency guidance materials.  As you know industry and, in particular, trade associations have taken issue with guidance materials as there has not traditionally been a method to provide comment on these materials prior to issuance.  Often, interested parties view guidance as de facto rulemaking.   Another interesting question is whether or not interpretations issued by agencies such as PHMSA constitute guidance and will be subject to the intensive review outlined in the EO.  EO #13892 focuses on an agency’s use of guidance material in enforcement actions, ensuring sufficient notice from agencies of legal standards measuring compliance, and mandates new rules for agency inspections and collection of data.

Department of Transportation (DOT) Secretary Elaine Chao, speaking in Florida at the Florida TaxWatch annual conference, emphasized the administration’s deregulatory efforts. “The results have been spectacular,” Chao said, as quoted in the publication Florida Politics. Florida TaxWatch is a taxpayer watchdog. According to Chao, regulatory costs at DOT have decreased by a net of $3.7 billion during the Trump administration.

Principal Deputy Assistant Secretary Loren Sweatt of the Department of Labor, Occupational Safety and Health Administration, recently addressed the attendees of a conference in Pennsylvania.  At the conference, Loren Sweatt focused on OSHA’s balanced approach to workplace safety and health. She noted that strong enforcement will always be a priority but the agency’s focus on outreach through compliance assistance is also key. For employers who understand their responsibiities, OSHA provides compliance assistance to give employers and workers the tools they need to keep workers safe. You can view her address here.

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The American Transportation Research Institute (ATRI) recently published a report which states the costs associated with trucking in 2018 have increased by 7.7.%  over 2017. The report entitled,  “An Analysis of the Operational Costs of Trucking,” shows fuel and driver compensation accounted for carriers’ biggest expenses while permits and licenses accounted for the smallest. According to the report, the average marginal cost per mile incurred by motor carriers rose to $1.82, a 7.7% increase from 2017’s cost of $1.69. The report states that costs are the highest since data collection began in 2008.

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People, Places & Things

On December 3, 2019, The California Air Resources Board (CARB) announced suspension of enforcement for at least two years of its greenhouse gas (GHG) standards. The new standards had been set to go into effect January 1. These standards are similar to the delayed federal GHG emission standards for trailers.