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The Journal of HazMat Transportation

A Publication of PRI International, Inc.

Volume 26, Number 6 March/April 2016

In This Issue


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

Also go to, 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, please login to and go to Critical Dates: Compliance Dates.  Summaries are linked to our reports and Federal Register notices.

Alerts Since Last Issue

HazMat Alerts Issued by The Journal of HazMat Transportation since publication of the November/December 2015 issue



A Summary Review of Recent and Important DOT Letters of Interpretation of the Hazardous Materials Regulations from January, February, and March 2016.

  • Hazard Communication for Certain CO2 Fire Extinguishers
  • Category B Performance Packaging Requirements 
  • Displaying the Limited Quantity Mark on a Freight Container
  • Affixing Placards with Duct Tape
  • Clarification of Closure Instructions for Category B Infectious Substances
  • Carriage by a Passenger of a Lithium Ion Battery Pack
  • Rendering a Condemned Cylinder Unusable
  • Wet Batteries Packed with Other Materials
  • Category B packaging

By Ed Mazzullo, Technical Advisor



A Look at the OSHA and DOT Hazcom Requirements for Large Transport Containers
By Frits Wybenga, Senior Technical Advisor

Implementation of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) into US OSHA’s Hazard Communication Standard (HCS) continues to raise questions about DOT requirements and letters of interpretation. This report examines how and what must be displayed on large volume hazmat containers in transportation and addresses potential confusion with DOT placards.

OSHA Publishes Guidance for HazCom 2012
By Michele Sullivan, Ph.D., Technical Advisor

The US Occupational Safety and Health Administration published Hazcom 2012 Hazard Classification Guidance (OSHA 3844), Hazard Classification Guidance for Manufacturers, Importers, and Employers, on February 12, 2016. Dr. Sullivan provides an overview of the document and information on how to submit comments to OSHA on its draft Guidance on Data Evaluation for Weight of Evidence Determination.



Transport Canada Move to Increase Harmony with International Regulations
By Barbara Foster, Dangerous Goods Specialist, ICC Compliance Center

Like US’ DOT and Federal agencies around the world, Transport Canada is in the process of harmonizing with international standards, in particularly the United Nations Model Regulations on the Transport of Dangerous Goods (UN Recommendations). This report provides an overview of some of the most significant sections of proposed amendments to Transportation of Dangerous Goods Act and Regulations (TDG) to incorporate changes from and harmonize with the 19th UN Recommendations, the 2015-2016 ICAO Technical Instructions, as well as increase reciprocity with the US.



NTSB Issues New Safety Recommendations for Lithium Batteries Transported as Cargo on Aircraft
By Ed Mazzullo, Technical Advisor 

The US’ National Transportation Safety Board (NTSB) issued two safety recommendations to the Pipeline and Hazardous Materials Safety Administration (PHMSA) on the subject of transporting lithium batteries as cargo on aircraft. The recommendations to require segregation and maximum loading density requirements exceed current ICAO requirements and will most likely be raised by the US at an international level. Mr. Mazzullo discusses the recommendations and background behind them.



JHMT Responses to Questions Regarding Limited Quantities, Reuse of Packagings in China, Emergency Response Information in the Air Mode, and Use of an Overpack in the Air Mode
By Frits Wybenga, Senior Technical Advisor

Mr. Wybenga tackles four questions raised by Journal readers and goes in-depth to explain and elaborate on limited quantity provisions for flammable liquids; international regulations applying to the reuse of packagings; compliance with emergency response information; and the notation of overpacks on air shipment transport documents.



State Rail Fee Collection and Equipment Sharing: Report from the Regional Railroad Accident Preparedness and Immediate Response Fund Advisory Committee in California
Edward W. Pritchard, Senior Partner, Paladin Consulting Group

This report covers the Regional Railroad Accident Preparedness and Immediate Response Fund Advisory Committee at Mather, California, on March 8, 2016. Mr. Pritchard provides the agenda topics and an overview of discussion and action at the meeting. This report contains a sidebar announcing Union Tank Car opening a new tank car facility to retrofit tank cars as required under HM-251.



A Look at Selective Testing Provisions for Non-Bulk Packagings and Related Interpretations—Part A: Combination Packagings
By Ed Mazzullo, Technical Advisor

Mr. Mazzullo dives into letters of interpretation issued by PHMSA on the subject of combination packagings. He comments and provides guidance on such subjects as periodic retesting, definition of different packaging, variations in inner packaging, “superpacks,” variations for outer packagings without further testing, variations for inner receptacles for infection substance packagings, and test records.



Type IP-2 or IP-3 Qualification under the Alternate ISO 1496-1 Standard 
By Wade Winters, President, Regulatory Resources

This report covers aspects of qualifying ISO 1496-1 freight containers for use as a Type IP-2 or IP-3. Wade Winters provides expert guidance and information on the definition and use of freight containers.



Hazardous Materials Transportation Regulations—Part A:  Regulatory Highlights for 2015
Ed Mazzullo, Technical Advisor

Mr. Mazzullo provides this review of highlights of the past year rulemaking activities of the Department of Transportation’s (DOT’s) modal administrations of hazardous materials. PHMSA activity is a primary focus; its rulemakings are developed in coordination with other modal administrations the Federal Aviation Administration (FAA), the Federal Railroad Administration (FRA) and the Federal Motor Carrier Safety Administration (FMCSA) and, when appropriate, with the Coast Guard (USCG).  Certain FMCSA and FRA rulemaking actions are included.

Hazardous Materials Transportation — Part B: Preview of the 2016 Regulatory Agenda
By Ed Mazzullo, Technical Advisor 

In the second part of his regulatory review, Mr. Mazzullo looks at anticipated activity for 2016. Read for an idea of what to expect from PHMSA in terms of miscellaneous amendments, changes to lithium battery regulations, reverse logistics, bulk tanks, pressure vessels, rail safety, air transport, as well as relevant FMCSA and FRA activities.



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

  • Proper shipping name for liquids reclassed as combustible liquids
  • Package Testing Requirements for Biological Substances
  • Use of a Secondary Means of Closure
  • External Rail Tank Car Inspection


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: January and February 2016. Twenty-three letters sorted, indexed and provided verbatim.         

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