I have had a numerous discussions with companies regarding this new push for “trans-loading”. Trans-loading is defined as:
"Transloading means the transfer of a hazardous material by any person from one bulk packaging to another bulk packaging, from a bulk packaging to a non-bulk packaging, or from a non-bulk packaging to a bulk packaging for the purpose of continuing the movement of the hazardous material in commerce."
I am not sure what is driving this increase in interest in this activity, but all of the inquires were centered around a single question:
Is my trans-loading operation a PSM or RMP covered process?
And each time, the answer has been a clear YES. And I never hear from them again. In my recent travels, one such site that I was asked about was in operation. Now I could not see if they were practicing PSM in their activities; but I was able to verify an RMP had not been submitted for this process. The lawyers asking the questions, clearly did not expect my answer, and challenged it hard; but, that did not change the fact this would be BOTH a PSM and an RMP covered process.
Why?