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Current Issue

The Journal of HazMat Transportation

A Publication of PRI International, Inc.

 

Volume 25, Number 5 January/February 2015

 

In This Issue

RULEMAKING ACTIVITY

Summary of U.S. D.O.T. Rule & Rulemaking Activity

Also go to www. hazmatship.com, Critical Dates. Summaries are linked to our reports and Federal Register notices.

 

Compliance Dates:  For a summary of important international and U.S. compliance dates, go to www.hazmatship.com, Compliance Dates.  Summaries are linked to our reports and Federal Register notices.

 

PHMSA PENALTY VIOLATIONS

U.S. DOT, PHMSA CLOSED PENALTY CASES

 

HAZMAT TRANSPORTATION GUIDANCE

A Summary Review of Recent and Important DOT Letters of Interpretation of the Hazardous Materials Regulations from November and December 2014.

By Ed Mazzullo, Technical Advisor

 

UN REPORTS

Report on the 46th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods
By Frits Wybenga, Senior Technical Advisor

From Geneva, Mr. Wybenga reports on the decisions and discussion made at the fourth and final meeting of the 2013-2014 biennium. Read for a review of amendments adopted at that will be incorporated into the 19th edition of the UN Model Regulations and the 6th revised edition of the UN Manual of Tests and Criteria.

Results of the 28th Session of the UN Sub-Committee of Experts on the Globally Harmonized System
By Frits Wybenga, Senior Technical Advisor

Following the 46th session of the UN TDG Sub-Committee, the GHS Sub-Committee met for the last of four sessions held over the course of the 2013-2014 biennium. Mr. Wybenga provides this report on notable actions taken at that meeting. Decisions will be reflected in Revision 6 of the Globally Harmonized System of Classification and Labelling of Chemicals.

 

PHMSA RULES AND RULEMAKINGS

Harmonization with International Standards HM-215M: from NPRM to Final Rule  
By Frits Wybenga, Senior Technical Advisor, and Ed Mazzullo, Technical Advisor

This thorough review of the International Harmonization HM-215M follows its progress from notice of proposed rulemaking to final rule. Read for discussion of the wide-ranging adopted changes, detail on effective dates, as well as the changes not adopted in this rulemaking.

2014:  A Review of Regulatory Activity in Hazardous Materials
By Ed Mazzullo, Technical Advisor                                               

This review highlights last years’ hazardous materials-related rulemaking activities of the U.S. DOT’s modal administrations charged with regulating the transportation of hazardous materials

2015: A Review of Probable Hazardous Materials Regulatory Activity from the U.S. DOT in 2015
By Ed Mazzullo, Technical Advisor

PHMSA and the modal administrations started regulatory initiatives in 2014 and earlier in the form of rulemaking actions related to hazardous materials transportation that should action in 2015.

 

CANADIAN REGULATIONS

Canada’s Revision of the Transport of Dangerous Goods Regulations Aligns with UN Model Regulations and ICAO Ban on Lithium Metal Batteries on Passenger Aircraft
By Ed Mazzullo, Technical Advisor

In December 2014, Transport Canada published an amendment to the Transport of Dangerous Goods Regulations (TDGR), primarily intending to align provisions of the TDGR with the UN Model Regulations and other international standards for the first time since 1999. The amendment implements the ICAO ban on lithium metal batteries on passenger-carrying aircraft and adds emergency response assistance plan requirements.

 

HAZARD COMMUNICATION

The Potential for Confusion in Transport with Implementation of the GHS
By Frits Wybenga, Senior Technical Advisor

Acceptance staff face a challenge when checking packages for compliance. With Globally Harmonized System of Classification and Labelling of Chemicals (GHS) pictograms being used to indicate non-transport hazards and sometimes coinciding with DOT transport labels, the challenge is greatly increased. Mr. Wybenga takes an in-depth look at the possible issues arising from combinations of the hazard communication systems.

HazCom 2012: Are You Prepared for the Impending Changes?
By Michele Sullivan, PhD

As international deadlines approach for implementing GHS hazard communication standards, compliance in the US faces a significant change as OSHA’s Hazard Communication Standard shifts from a performance-oriented standard to a specification standard. Dr. Sullivan examines important elements of the change, including safety data sheets, labels, and supply chain communication.

 

DANGEROUS GOODS BY HIGHWAY

FMCSA Relaxes Driver Vehicle Inspection Reporting Rules and Suspends Enforcement of Certain HOS Restart Requirements 
By Ed Mazzullo, Technical Advisor

This report summarizes two recent actions taken in December, 2014: FMCSA rescinded a provision of the Federal Motor Carrier Safety Regulations, relieving most CMV drivers from the requirement to submit, and motor carriers to retain, driver-vehicle inspection reports when no vehicle defects or deficiencies are found. FMCSA temporarily suspended enforcement of certain provisions of FMCSA’s Hours of Service rules.

 

DANGEROUS GOODS BY RAIL

One State Takes Initiative on Addressing Bakken Crude Oil 
By Edward W. Pritchard, Senior Partner, Paladin Consulting Group

 The Industrial Commission of North Dakota adopted new conditioning standards in December. The order sets operating standards and requirements regarding conditioning of crude oil and includes parameters for temperatures and pressures under which the equipment must operate. Mr. Pritchard examines the actions of the Commission and relates it to the upcoming PHMSA Final Rule HM-251 regarding high hazard flammable liquids transport by rail.

 

COMMENTS ON DOT INTERPRETATIONS   

The Journal of HazMat Transportation’s Exclusive Comments on the U.S. DOT Letters of the Hazardous Materials Regulations
By Frits Wybenga, Senior Technical Advisor

  • Identification numbers on IBCs
  • Regulation of ping pong balls as Celluloid, UN 2000
  • Appendix 6 of the UN Manual of Tests and Criteria

 

U.S. DOT INTERPRETATIONS OF THE HMR

U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: November and December 2014. Seventeen letters sorted, indexed and provided verbatim.    

 

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