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The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 27, Number 2 July/August 2016

In This Issue 

PHMSA Penalties:  March through June 2016       


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, and go back several years.

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.




A Summary Review of Recent and Important DOT Letters of Interpretation of the Hazardous Materials Regulations from May through July 2016.

  • Hot Water Bath for Aerosols      
  • Marking Inlets and Outlets On MC331 Cargo Tanks           
  • Prohibited Placarding
  • Shipping Name for Lithium Metal Battery Packs
  • Exceptions for Medicines Containing Ethyl Alcohol  
  • Transport of an Activated Device Containing Lithium Metal Cells
  • Chemical Etching for Cylinder Markings
  • Applicability of the HMR to Transport of Explosives under Three Scenarios

By Ed Mazzullo, Technical Advisor



National Transportation Safety Board Round Table Discussion a Dialogue on What's Next in Rail Tank Car Safety   
By Edward W. Pritchard, Senior Partner, Paladin Consulting

Mr. Pritchard provides this report on discussion at the recent roundtable discussion held by the National Transportation Safety Board. Chief among topics of discussion were implementation of the FAST Act, shipments of crude oil, tank car safety, and others.



Update on SOLAS Requirements for Container Weight Verification
By Ed Mazzullo, Technical Advisor

An amendment to the International Convention for the Safety of Life at Sea, SOLAS Regulation VI/2, is mandatory beginning July 1, 2016 and requires verification by the shipper of a packed container’s gross mass prior to stowage of the container aboard a vessel. Mr. Mazzullo reviews the requirements and takes a look at an IMO MSC circular and USCG guidance.



Airgas Doral, Inc. Pleads Guilty to Fatal 2008 Incident, Sentenced by Department of Justice: $4.3 Million Fine, Organizational Probation, and $2.7 Million in Restitution      
By JHMT Staff

On May 5, 2016, Airgas Doral pled guilty to a tragic accident that took the lives of three longshoremen. Hazmat Consultant Robert Bunn and Senior Technical Advisor Gordon Rousseau provided a report in the March/April 2009 edition of The Journal titled Deadly Shipboard Accident Involving Argon Gas: Airgas South Receives Civil Penalty Notice; their report is included.

Criminal Case Concludes Against Airgas Doral, Inc. for Violations of Federal Hazardous Materials Law   
Roncevert Almond, Esq., The Wicks Group LLC

The Airgas case represents a relatively rare instance where violations of federal hazardous materials law result in a civil enforcement action and criminal prosecution. Legal expert Roncevert Almond takes a closer look at the legal proceedings of the case as well as the verdict.



Update on and Review of PHMSA’s HM-218H Miscellaneous Amendments Final Rule 
By Ed Mazzullo, Technical Advisor

PHMSA issued final rule HM-218H, which incorporated a number of changes to the hazardous materials regulations, with an effective rule date of July 5, 2016. A number of concerns arise from the changes, regarding packaging requirements for nitric acid, prohibition of alphanumeric emergency response numbers, appeals to the rule, and other concerns.

PHMSA Issues HM-219A NPRM Responding to Petitions for Rulemaking
By Ed Mazzullo, Technical Advisor 

In notice of proposed rulemaking HM-219A, PHMSA proposes to amend the Hazardous Materials Regulations (HMR) in order to update, clarify, or provide relief from miscellaneous regulatory requirements, largely in response to petitions for rulemaking from the regulated community. Read for a summary of changes in the NPRM.



Applying DOT HMR to Regulated Precious Metals Destined for Recycling 
By Wade Winters, President, Regulatory Resources Inc.

Regulatory expert Wade Winters examines some of the regulatory requirements for precious metals, touching on the nuances of compliance with the Resource Conservation and Recovery Act (RCRA), and comparing the difference in perspective on hazardous waste between the Department of Transportation and the Environmental Protection Agency.



Report on the 49th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods: June-July 2016        
By Frits Wybenga, Senior Technical Advisor

Senior Technical Advisor Frits Wybenga provides this report from Geneva summarizing the decisions and actions taken by the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods at its 49th session, held from June 27 to July 6, 2016. Read for a presentation of the discussion of the more substantive issues, organized by agenda item.



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

  • Criteria for passing the vibration test
  • Leakage testing of cargo tank trucks
  • Sufficient capacity of vacuum relief for portable tanks
  • Lithium battery compliance


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: May through July 2016. Thirty-four letters sorted, indexed and provided verbatim.   

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