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The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 25, Number 4 November/December 2014


In This Issue 1


Summary of U.S. D.O.T. Rule & Rulemaking Activity     44-46

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.






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

  • Minimal Thickness Marking for a UN1H2 Plastic Drum         11
  • Air Carriage of an Electro-Shock Weapon by a Law Enforcement Officer    15
  • Shipping Name for Select Agents        18
  • Performing a Pre-Transportation Function       23
  • Foreign Approval of Air Bag Inflators, Air Bag Modules, and Seat-Belt Pretensioners        26
  • Securement of Non-Hazardous Cargo in a Mixed Load         28
  • Category A Secondary Packaging       30
  • Providing Emergency Response Information  33

By Ed Mazzullo, Technical Advisor



 Pre-Meeting Report on Proposals to be Addressed at the 46th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods     31-35

Compiled by JHMT Staff, reviewed and commented upon by Frits Wybenga, Senior Technical Advisor

Read this report for summaries of and commentary on the proposals submitted to the upcoming session of the United Nations Sub-Committee. The proposals are presented in seven subject categories for the convenience of our readers. Topics include: Listing, classification, and packing; Explosives and related matters; Electric storage systems; Miscellaneous proposals of amendments to the Model Regulations; Guiding principles for the Model Regulations; Issues relating to the Globally Harmonized System of Classification and Labeling of Chemicals; and Informal papers.



 PHMSA’s HM-253 NPRM on Reverse Logistics: Caution Advised                    7-11

By Frits Wybenga, Senior Technical Advisor

 PHMSA’s HM-253 NPRM, published August 11, 2014, proposes to revise the Hazardous Materials Regulations applicable to return shipments of certain hazardous materials in the reverse logistics supply chain. Mr. Wybenga presents potential complications and possible over-extensions of the proposed rulemaking in this in-depth report.



 A Dissection of the HM-250 Revised 173.443         36-41

By Wade Winters, CEO, Regulatory Resources Inc.

 This extensive Part 2 review of PHMSA’s HM-250 Compatibility with the Regulations of the International Atomic Energy Agency addresses each paragraph of the Final Rule. More than that, Mr. Winters helpfully begins by examining the definitions of important terms used in the docket and this article. Study this report for changes to the Class 7 (radioactive) material transport regulations that may impact you.


PHMSA Enforcement

Report from the Field: An Update from PHMSA Field Operations        27-28

By Ronce Almond and Glenn Wicks, The Wicks Group, LLC

 This article builds on an October 16, 2014, update given by PHMSA on the status of PHMSA field operations and enforcement approach. Read for a better understanding of PHMSA’s goals and current activities, as well as informative context.



 Report on the October Meeting of the International Civil Aviation Organization’s Dangerous Goods Panel Working Group                      12-16

By Geoff Leach, Director, Dangerous Goods Office Ltd.

Former Chairman of the ICAO DGP Geoff Leach reports on the results of the first meeting of the biennium of the Working Group. Each working and information paper is summarized and the WG’s decisions or actions on each are presented. Lithium batteries were one area of large concern, in addition to topics on training, packing instructions, shipping names, among others.

Results of the Second Meeting of the Multi-Disciplinary ICAO Working Group on Lithium Batteries            29-30

By Geoff Leach, Director, Dangerous Goods Office Ltd.

 A second multi-disciplinary meeting was held in September, 2014, to review and discuss the hazards associated with the shipment of lithium metal and lithium ion batteries in passenger and cargo aircraft cargo compartments; andto develop mitigation strategies as needed. Mr Leach provides The Journal with the recommendations made from the report of the meeting.



IMO Updates: IMDG Amendment 37-14; MSC 94 SOLAS Amendment: Container Weight Verification                        25-26

By Ed Mazzullo, Technical Advisor

This report examines the changes between Amendment 36-12 and Amendment 37-14 in the 2013 edition of the IMDG code intended to harmonize with changes in the 18th Revised Edition of the United Nations Model Regulations as well as changes made to address IMDG-specific issues. Read for highlights of changes as well as more depth on the issue of the expected final adoption of a draft amendment to SOLAS to require verification of container weight.



Recent Shortcomings Observed at Chemical Facilities that Ship by Rail            17-18

By Edward W. Pritchard, Senior Partner, Paladin Consulting Group

 This report addresses recent instances of non-compliance that was observed at two chemical facilities that ship hazardous materials by rail. Mr. Pritchard offers critical observations regarding security plans, tank car loading/unloading operations, inspection of inbound tank cars, and other areas an inspector may focus on.



 The Journal of HazMat Transportation’s Exclusive Comments on the U.S. DOT Letters of the Hazardous Materials Regulations                       19-24

By Frits Wybenga, Senior Technical Advisor

 - Flashpoint Notation for Vessel Transport

- Useful Life Limit Requirements for TIH Rail Tank Cars

- Class 9 Label Crisis



U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: September and October 2014. Thirty-one letters sorted, indexed and provided verbatim.    


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