Flying with Lithium Powered Laser Plasma Lighters

One pack of safety matches, a BIC or a ZIPPO lighter, is allowed when carried on or in carry-on baggage. On the other hand lighter fuel, lighter refills and lighters containing unabsorbed liquid fuel, are not, as it has been and continues to be the case under the 49 CFR, Pipeline and Hazardous Materials Safety Administration in 175.10(a)(2) Exceptions for passengers, crewmembers, and air operators.

What’s new is lithium battery powered laser plasma lighters, tesla coil lighters, flux lighters, single and double arc lighters, will now be required to meet UN Testing and Criteria recommendations. In addition, these lighters must be equipped with a means to prevent unintentional activation of the heating element and passengers and crew should be aware the recharging of these devices on board the aircraft is not permitted.

Each battery's lithium content must not exceed 2 grams for lithium metal batteries, and for lithium ion batteries, a Watt- hour (Wh) rating of 100 Wh. All per the May 11, 2020 PHMSA final rule amending the domestic Hazardous Materials Regulations (HMR) to maintain alignment with international regulations and standards.

Link to Federal Register:
https://www.govinfo.gov/app/details/FR-2020-05-11/2020-06205  (starting page 27898)

Robert J Keegan 
Hazardous Materials Publishing Company
Transportation Skills Programs Inc
www.hazmat.tsp@gmail.com 

Follow me on my HazMat Rob facebook page for insights:
https://www.facebook.com/hazmat.rob.5

DOT DIRECTS HAZARDOUS MATERIAL SHIPPERS TO ACCESS ONLINE TRAINING

The Department of Transportation, (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA), did not suspend training, only the requirements of how it is done. Think of it like your mortgage payments.

“PHMSA gives notice that it will not take enforcement action for 90 days (from March 25.2020), against any hazmat employer who is unable to provide recurrent training consistent with HMR training requirements.” 

Check out the recent Notice of Enforcement letter, in which DOT promotes alternatives to traditional compliance training methods; https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2020-03/PHMSA%20Enforcement%20Policy%20Notice%20-%20TRAINING%20update.pdf

If hazardous materials and waste training can not be provided in a classroom setting or traditional job training, DOT directs hazmat employers to access web based, cellphone, tablet or computer remotely delivered classroom instruction, or any other method, that will cover the required training elements, to provide hazmat employees with appropriate recurrent training even if testing is not possible. 

But be careful, as I said, I think it is kinda like your mortgage payments, your mortgage company is not allowing you to push back your payments for three months, they are only saying we will give you three months, to pay us the money you owe over the next three months.

If you need it, attend one of our small online Hazardous Materials, Substances and Waste Training courses, and receive our new customizable Pandemic Preparedness and Prevention Plan, (PPPP) and Checklist to get you fully up to speed. Do it alone, with us or someone else, but do something now.

Thank you hope to see you soon!

Robert Joseph Keegan 
Publisher and President 
Hazardous Materials Publishing Company
Transportation Skill Programs Inc. 
hazmat.tsp@gmail.com

PREPARE AN OSHA PANDEMIC PREPAREDNESS, PREVENTION AND TRAINING PLAN NOW!

Protecting workers from this and future pandemics will be the major focus of OSHA worker protection 29 CFR initiatives, in the coming weeks, months and years. You will need a Pandemic Preparedness and Prevention Plan (PPPP), for currently working and returning workers. OSHA has already published strict guidelines for protecting workers for this and other pandemics that might threaten our country and economy 

Basic Infection Prevention Measures 

You must immediately Implement policies on:

• The frequent and thorough hand washing, including those of workers, customers, and worksite visitors, including where to find tissues and trash receptacles. 

• The need of workers staying home if they are sick.

• Respiratory etiquette, including covering coughs and sneezes.

• The practices you have established; such as flexible worksites and work hours including social distancing strategies.

• The nonessential use of other workers’ phones, desks, offices, or other work tools and equipment. 

• The company’s housekeeping practices, including the routine cleaning and disinfecting of surfaces, equipment, and other elements. 

• The use of all cleaning and disinfection products (e.g., concentration, application method and contact time and any PPE requirements).

Pandemic Preparedness and Prevention Plan (PPPP)

Your PPPP must address:

• Where, how, and to what sources workers could be exposed, including: the general public, customers, and coworkers;

• The non-occupational risk factors to workers at home and in community settings;

• Workers’ individual risk factors (e.g., older age; presence of chronic medical conditions, including immunocompromising conditions; pregnancy);

•  High turnover and rates of worker absenteeism;

• The use of social distancing, by staggered work shifts, downsizing operations, delivering services remotely, and other exposure-reducing measures;

• The recording and reporting of occupational injuries and illness;

• The continuation of essential operations with a reduced workforce, by cross-training key workers across different jobs in order to continue operations or deliver surge services; and

• Emergency sourcing, supply, warehouse and delivery chains 

Policies and Procedures for Prompt Identification and Isolation of Sick and Healthy Employees.

 Implement policies that detail:

• How employers should inform and encourage employees to self-monitor for signs and symptoms, when they suspect possible exposure.

• To who or by what process can employees report when they are sick or experiencing symptoms.

• The immediate isolation of workers who have signs and/or symptoms, and correct ways in which to move potentially infectious people to locations away from workers, customers, and other visitors.  

• The use of specific isolation rooms, such as areas with closable doors to house workers, until a potentially sick person can be removed from the worksite. 

• The differences between PPE and a face mask. 

• The protection of workers in close contact with a sick person or any worker who has had prolonged, repeated or suspected contact with one.

Sign up for one of our live online seminars and receive a copy of the Pandemic Preparedness and Prevention Plan (PPPP) and checklist. And if you have questions or require help with a site specific PPPP for your company, don’t hesitate to call or contact us. Don’t be caught off guard next time. “Prepare Now”.

Thank you,

Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc.
hazmat.tsp@gmail.com
(610)683-6721

WE’RE GETTING THE BAND, BACK TOGETHER ……….ONLINE!

I feel that I am “preaching to the choir” when I write about our gratitude and respect for those of you in government positions and essential industries pushing forward right now, at work or home, whether by choice or necessity, at this uncertain time, our families, both personally and professionally, thank you. 

I am sure, you like us, are short staffed and are being asked to do unfamiliar jobs, so we want you to know, first and foremost we are here (https://www.hazmat-tsp.com) as always, at no cost, to answer your questions and to address any of your concerns. 

DOT EPA OSHA GUIDEBOOK 

Having the current DOT, EPA and OSHA regulations available for compliance and for training workers, is key to meeting your worker protection, environmental and transportation commitments. Your employees need now, more than ever the proper information, certifications and support. 

This year we have really “pulled out all the stops” in the new 2019/2020 HAZARDOUS MATERIALS, SUBSTANCES and WASTES COMPLIANCE GUIDEBOOK  (https://www.hazmat-tsp.com/complianceguide). 

The 2000 page Guidebook, with it’s test and training certificates, can be shipped to businesses, individual home addresses, in fact anywhere you need, to use for work or to train your people online. Order now!

LIVE ONLINE SEMINARS and WORKSHOPS

You will need your people to be working when they get back, not training.“The show must go on”. So, the 2019/2020 HAZARDOUS MATERIALS, SUBSTANCES and WASTES COMPLIANCE and CERTIFICATION SEMINARS, as well as our customized online in-house, ICAO/IATA and special permit training will still be available online (https://www.hazmat-tsp.com/seminars) for hazardous material and waste shippers, hazardous waste generators and employees exposed to hazardous substances.
Certify in place, at one or 100 locations. Train, test and certify with an experienced online, live instructor. Don’t wait up, reserve your space. Sign up!

REGULATORY UPDATES and LINKS

It is not going to be “the same old song and dance” so, in addition to Rob’s DOT, EPA and OSHA blog, links, information and guidelines, we have included, among other information, the current OSHA worker protection coronavirus recommendations (https://www.osha.gov/Publications/OSHA3990.pdf), 

Sign up for a free copy of the changes to the hazardous material, hazardous waste and hazardous substance regulations out of the Federal Register (https://www.hazmat-tsp.com/federalregister). Go online now!

INFORMATION ON LOANS AND GRANTS

And to those of you at home, who cannot work, thank you for your sacrifices too. I can't imagine not being able to work, and, at the same time not being able to see and spend time with the people that you love and care about, especially now when many of them, at times feel isolated and vulnerable, that, makes it unbearable. 

Go online to the Small Business Administration (https://www.sba.gov/page/coronavirus-covid-19-small-business-guidance-loan-resources) and get help, keep your people working, there are going to be a lot of empty warehouses that will need to be refilled. You need to be ready. Apply now!

BE READY WHEN CALLED

We are going to have to “play it by ear” so for now, visit our website (https://www.hazmat-tsp.com/) to order a guidebook or to arrange for your online training, so you're ready when called. Please remember you can still call or email if you have any questions or concerns. See you soon.

Robert J. Keegan (Lead singer)
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc.
610-683-6721

Questions can be sent to  hazmat.tsp@gmail.com  

CONSISTENT AND REPEATABLE

CONSISTENT AND REPEATABLE 

Shippers of hazardous materials and generators of hazardous waste are required to retain and make available upon request, a copy of the packaging manufacturer's closure instructions and notifications, for inspection by representatives of the Department of Transportation for at least 90 days, after an authorized DOT/UN package is offered to the initial carrier for transportation.  

PACKAGING INSTRUCTIONS

The instructions must provide a consistent and repeatable means of closure, (ie: the use of torque wrenches) sufficient to ensure the packaging is closed in the same manner as when the container was run through the drop, vibration, stacking and leakproof tests under the 49 CFR Department of Transportation Hazardous Materials Regulations and the 40 CFR Environmental Protection Agency Hazardous Waste Management System.

SHIPPERS PACKAGING RESPONSIBILITIES 

It is the hazardous material and waste shippers’ burden to ensure that the packaging they select has been manufactured, assembled and marked, in accordance with EPA 40 262.30 and DOT 49 CFR sub-paragraphs 171.1(b),(2),(3),(4), Part 173 Shippers requirements for shipments of packaging, Part 178 Specifications for packagings or Part 179 Specification for tank cars. This would include applying the correct packaging closures, gaskets or other components that shippers of DOT hazardous materials and EPA hazardous wastes, need to ensure that the packaging is capable of successfully passing the manufacturer’s tests.

MANUFACTURERS, DISTRIBUTORS AND CONTRACTORS PACKAGING RESPONSIBILITIES

The manufacturer, any other person certifying compliance, each subsequent distributor and waste contractor who provide containers, under DOT 49 CFR 178.2, must provide the person to whom that packaging is transferred, at the time of transfer, all applicable closure and notification requirements, retain copies of each written notification for at least 1 year from the date of issuance; and make copies of all written closures and notifications available for inspection by representatives of the Department.

INNER PACKAGING AND RECEPTACLES

This information must also include the procedures and closure instructions to be followed for any required inner packaging or receptacle, so that they are effectively assembled and closed once placed into outer packaging to prevent leakage.

PRESSURE TESTING

And remember, packagings sold or represented as being in conformance for transportation by aircraft, the information must include proper guidance to ensure that the packaging, when prepared, will withstand the pressure differential requirements in DOT 49 CFR Section 173.27(c).

HARD COPY

Closure instructions and notifications must be conveyed to the shipper, in writing, by electronic means, including text, email or CD. (Note: If manufacturers testing companies and subsequent distributors utilize electronic means, the notification must be specific to the packaging and capable of being printed in hard copy)

REOFFERED PACKAGING

Subsequent offerors of a filled and otherwise properly prepared unaltered packaging are not required to “maintain” the manufacturer’s closure instructions, however they could still be fined if they were to reoffer a hazardous material or waste in an improperly closed container.

ARE YOU CLOSING YOUR CONTAINERS CORRECTLY?

If you have any questions or concerns about your cylinders, containers or tanks, call, email or sign up for our next hazardous materials and waste management seminar or contact us for in-house training.

Thank you for your readership and support.

Robert J. Keegan

Publisher and President 

Hazardous Materials Publishing Company

Transportation Skills Programs Inc.