Wednesday, January 30, 2013

DOT Updates Courtesy of NAFED


DOT Updates for Jan. 2013

The DOT has issued its final rule regarding the transportation of fire extinguishers. Read on to learn the latest updates.
The United States Department of Transportation, Pipeline and Hazardous Materials Administration (PHMSA) has issued a final rule regarding Docket No. PHMSA-2009-0126 (HM-215K); RIN 2137-AE83.

This final rule has a major impact on the transportation of fire extinguishers. NAFED’s federal regulations committee has reviewed this final rule and will submit a more detailed report in the near future. Detailed information will also be provided at NAFED’s DOT Train-the-Trainer Seminar in Austin, Texas, on March 1, 2013. In addition, a four-hour pre-conference DOT seminar is scheduled for all three of NAFED’s 2013 conferences. For more information and to register for any of these seminars please visit the event calendar.

Some of the key points addressed in this new rulemaking are:
  1. Fire extinguishers that are being transported to or from a facility for service (e.g., recharging, hydrostatic testing, internal maintenance, etc.) may be transported as Material of Trade (MOT) in accordance with CFR 49 §173.6. This would include carbon dioxide fire extinguishers or other fire extinguishers that do not meet the DOT 173.309 definition of fire extinguisher. Please note that the maximum amount of MOT allowed by the regulations is 440 pounds. Also all fire extinguishers transported as MOT must be labeled and marked as per Table 172.101 (UN1044, Fire Extinguisher; UN1013, Carbon Dioxide, etc.)
  2. 49 CFR §173.309, Fire Extinguisher, was drastically revised by the DOT. This section was reorganized to clarify the requirements based upon the type of cylinder used. Series 3 and 4 specification cylinders are addressed in §173.309(a), specification 2P and 2Q cylinders are addressed in §173.309(b), and non-specification cylinders are addressed in §173.309(c)
  3. §173.309(c) (5) states: “Each non-specification fire extinguisher must be packaged as an inner packaging within a combination outer packaging. Examples of acceptable outer packagings for non-specification fire extinguishers include large cartons, racks, cages, or other suitable enclosures.”
  4. §173.309(d) states that fire extinguishers shipped as limited quantity “are excepted from shipping papers (except when offered for transportation by aircraft or vessel), labeling (except when offered by transportation by aircraft) placarding…”
NAFED’s federal regulations committee recommends the following for compliance:
  • Any fire extinguisher that is not enclosed in a carton should have a label indentifying it as a UN1044 Fire Extinguisher.
  • All fire extinguishers must be properly secured in the vehicle at all times when in transportation.
  • Stored-pressure wheeled units must be labeled and included on a shipping paper.
  • Currently all packagings containing Limited Quantity fire extinguishers may be marked with UN 1044 Fire Extinguishers up until the end of 2014. After that time, with the new requirement, the outside packagings will have to be marked with the Limited Quantity square-on-point limited quantity label shown in CFR 49 §172.315.

NAFED realizes that there may be some confusion with these latest changes so we are offering the training opportunities listed above, and we will issue additional information at a later date. As with any major regulatory change, there can be different interpretations. The federal regulations committee wishes to provide an accurate analysis of these regulations and, if required, we will submit formal requests for interpretations.

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