Tuesday, May 26, 2015
Text Size

Current Issue

The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 25, Number 6 March/April 2015


In This Issue 1


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, also 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 January and February 2015.

  • Size of PSN and ID Numbers on IBCs Labeled instead of Placarded
  • Highway Shipment of Drums Containing only the Residue of a Hazardous Material
  • Handling Document for Small Lithium Batteries 
  • Approval of Foreign Air Bag Inflators Produced at Multiple Locations
  • Shipment of Liquid Nitrogen in Open Cryogenic Receptacles 
  • Continued Use of Packages Pre-Printed with "DOT-SP 9275" 
  • Name of Lading on a Cargo Tank under Special Provision B85 
  • Reflective Color for MC-331 Cargo Tanks
  • Passenger Aircraft Quantity Limits for Div 2.2 Gas with Subsidiary Hazard  

By Ed Mazzullo, Technical Advisor


A Report on the Changes and Decisions Made by the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods in the last Biennium (2013-2014) 

By Frits Wybenga, Senior Technical Advisor

Mr. Wybenga combines his experiences in Geneva over the last biennium with a UN document listing amendments to be introduced in the 19th revised edition of the Model Regulations.  In this report, he summarizes significant changes he expects to see reflected in PHMSA’s next HM-215 rulemaking, as well as updates to editions of international regulations.

The UN’s Continuing Effort to Establish a Generic Approach for Dangerous Goods in Machinery, Apparatus, and Articles

By Frits Wybenga, Senior Technical Advisor

The UN Sub-Committee of Experts on TDG will be carrying its efforts over from the last biennium to develop a generic approach for dealing with articles containing dangerous goods. This report covers principles of the United Kingdom’s draft proposal, potential safety concerns, and thus far unresolved issues.


PHMSA Publishes HM-218H Miscellaneous Amendments Proposed Rulemaking

By Ed Mazzullo, Technical Advisor

PHMSA published HM-218H Notice of Proposed Rulemaking on January 23, intending to update and clarify provisions of the Hazardous Materials Regulations. In it, PHMSA addresses seven petitions for rulemaking and two National Transportation Safety Board recommendations. PHMSA is proposing over 40 changes to the HMR to update, clarify or correct current provisions of the HMR; this report synopsizes those proposed changes.

PHMSA Issues HM-233F Proposed Rulemaking to Incorporate Almost 100 Special Permits into the Hazardous Materials Regulations

By Ed Mazzullo, Technical Advisor

PHMSA published a notice of proposed rulemaking proposing to amend the HMR to adopt provisions contained in certain widely-used or long-standing special permits that have an established safety record. Under section 33012(b) of MAP-21, regulations must be issued by October 1, 2015. Read this report for a summary of rulemaking proposals addressing: Cylinders - NDT/Aerosols; Cargo Tanks/Rail Cars/Portable Tanks; Operational Air/Vessel; Operational Highway/Rail/Shipper/Other; and Bulk Packaging Specifications/IBCs.



Enforcement Guidance for OSHA’s Hazard Communication Standard’s June 1, 2015 Effective Date

By Michele Sullivan, PhD

The June 1 deadline of OSHA’s revised Hazard Communication Standard is fast approaching, and in response to petitions by trade associations to extend the deadline for HCS 2012-compliant labels and SDSs, OSHA issued Enforcement Guidance for the Hazard Communication Standard’s June 1, 2015 Effective Date. Dr. Sullivan examines this enforcement guidance for its key elements, suggestions for documentation, and time periods given for compliance.

Marking/Labeling/Placarding Requirements between the U.S. HMR and the IMDG; and

Class 9 Materials En Route to a Port Facility for Marine Transport 

Answered by Frits Wybenga, Senior Technical Advisor

These questions come from an overseas shipper of hazardous materials by vessel. The first question regards conforming to the HMR or IMDG Code for marking IBCs containing certain liquid dangerous goods; the second question concerns the applicability of driver hazmat certification requirements when transporting placarded class 9 materials to port facility.

Marine Pollutant Exceptions under § 171.4

Ed Mazzullo, Technical Advisor

Mr. Mazzullo responds to concerns that recent changes under HM-215M may have affected the broad exception from marine pollutant requirements for non-bulk packagings transported by motor vehicle, rail car, or aircraft.

Marine Pollutants in the IMDG Code

Frits Wybenga, Senior Technical Advisor

Mr. Wybenga takes a question about the classification of zinc oxide as a marine pollutant and examines the larger picture of the difficulties that can arise in classification of items for international shipping. His answer provides valuable information for international shippers concerned with variance in national criteria.

GHS Comes to Canada – the New Hazardous Products Regulations

By Barbara Foster, Dangerous Goods Specialist

Under Health Canada’s Hazardous Product Act, the Controlled Product Regulations (CPR) regulation established criteria for classifying hazardous workplace substances, as well as the requirement for supplier labels and Material Safety Data Sheets (MSDSs). The CPR is the core regulation of Canada’s Workplace Hazardous Materials Information System (WHMIS), in use since 1988. On February 11, Health Canada published the Hazardous Products Regulations (HPR) in the Canada Gazette, introducing the GHS classification system. Read this report for information on implementation, differences and similarities between the HPR and Hazcom 2012, and how to prepare for GHS in Canada.



Who Will Pay For Cleanup Of Crude Oil Derailments?

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

As shipments of crude oil by rail continue to increase in North America, so have reported incidents. A large-scale disaster can bankrupt those held liable, with cleanup costs exceeding insurance coverage. Mr. Pritchard looks at current insurance requirements for railroads as well as proposed amendments to Canadian rail regulations, which include a new liability and compensation regime for federally-regulated railways, minimum insurance requirements, among other proposed changes.


Limited Quantity Exceptions for Transport by Motor Vehicle

By Ed Mazzullo, Technical Advisor

Mr. Mazzullo summarizes and paraphrases PHMSA’s responses to a lengthy list of questions from a company located in Mexico. The issues concern the requirements for transporting limited quantities by motor vehicle.



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

  • Co-location of UN number and proper shipping name on a package
  • Damaged package
  • Return of empty packages containing residue


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: January and February 2015. Twenty-two letters sorted, indexed and provided verbatim. 

 Copyright 2015, PRI International, Inc. All Rights Reserved.

 The Journal of HazMat Transportation and its Digital Edition is published bi-monthly and HazMat Alerts are issued severally per month by PRI International, Inc. Subscription licensing inquiries and letters to The Journal of HazMat Transportation should be directed to PRI International, Inc., P.O. Box 3144, West Chester, PA 19381-3144, tel. 610-436-8292, or fax 610-436-9422. E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

IMPORTANT NOTICE: Reproduction or derivation of content for external or internal redistribution via print, electronic, or otherwise, of any part of this publication, print or electronic, without special prior written permission or from the publisher, is prohibited under Title 17 USC,  or unless commercial arrangements otherwise have been made via subscription license. Violators may be subject to fees by PRI International, Inc. PRI International, Inc. will vigorously enforce its intellectual property rights provided by United States and International law against all violators.

Electronic redistribution or electronic posting via web methods of verbatim or derived content from The Journal of HazMat Transportation (print and digital), HazMat Compliance Alerts, The HazMat Reference Gateway™, and The HazMat Compliance DataBase™ is strictly prohibited unless by specific arrangement or license. Content is reserved for the sole use of the subscriber by name while both content licensing and single and multiple user agreements are available which provide for internal content distribution rights to that subscriber(s). Call 877-429-7447 for information.  Complete intellectual property provisions and guidelines for use are found at www.hazmatship.com.


PRI International, Inc. hereby disclaims responsibility for any statements made or opinions expressed in its publications by individual contributors. 

  • 2015-28 May 21, 2015 Results of the 2015 ICAO Dangerous Goods Panel Working Group Meeting April 27 – May 1

  • 2015-27 May 19, 2015 Pre-Meeting Report on Proposals to be Discussed at the 47th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods

  • 2015-26 May 18, 2015 PHMSA Issues Best Practices Guide for Cargo Tank Loading/Unloading

  • 2015-25 May 11, 2015 Analysis: PHMSA’s HM-251 Final Rule: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains

  • 2015-24 May 8, 2015 PHMSA Issues HM-251 Final Rule: Enhanced Tank Car Standards and Operational Controls for High Hazard Flammable Trains