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Reshipping of Packaged Hazardous Materials

By Sonia Irusta
Dangerous Goods Bureau

It is a common practice in the transportation industry to reship packaged hazardous materials, most commonly for distribution purposes. Is this acceptable?  Yes, it is, provided the reshipper fully complies with all Federal and International regulations applicable to the mode(s) of transportation being utilized (highway, air, vessel or rail). 

As noted in Title 49 of the U.S. CFR, a person who either receives hazardous materials from another company and reships them (reshipper/offerer), or accepts a hazardous material for transportation, and transports that material (carrier), is responsible for ensuring that the shipment complies in all respects with Federal hazardous materials transportation law. In both cases, the reshipper or carrier independently may be subject to enforcement action if the shipment does not comply.

Reshipping a package of hazardous materials that was received as damaged, mis-declared, undeclared or simply not prepared in full compliance with the regulatory requirements is a violation of the law if the shipment is not brought to full compliance by the reshipper prior to it being offered for transport.   Appendix A to Subpart D of Part 107—Guidelines for Civil Penalties sets forth the guidelines PHMSA uses in making initial baseline determinations for civil penalties. The first part of these guidelines is a list of baseline amounts or ranges for frequently-cited probable violations. Following the list of violations are general guidelines PHMSA uses in making penalty determinations in enforcement cases.

Violations of the Federal hazardous materials transportation law are preventable!

Proper training in compliance with the  49 CFR Subpart H-Training requirements is the solution.

Think before you RESHIP!

Sonia Irusta is a highly accomplished business and technical professional instrumental in domestic and international transportation solutions for shippers, freight forwarders and carriers.  She can be reached at Bureau of Dangerous Goods (609) 860.0300 Ext. 327  or via E-mail

 

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