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The Journal of HazMat Transportation

A Publication of PRI International, Inc.

Volume 24, Number 6 March/April 2014

In This Issue 



Compliance Dates: 


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

(Also go to www., Critical Dates)






  • Periodic Retest for Packaging Design Tested with Different Closure Methods       
  • Applicability of the HMR to Aircraft Overflying the U.S. 
  • Affixing a Label to a Cylinder if the Label is either Missing or Destroyed 
  • Using a Placard Holder for Non-Hazardous Material    
  • Exceptions for Battery-Powered Equipment      
  • Disinfectant and Deodorizing Spray Described as Perfumery Products   
  • Requalification of Non-Specification Cylinders       




PHMSA Issues HM-233C Final Rule to Incorporate Certain Special Permits and Competent Authority Approvals into HMR       

By Ed Mazzullo, Technical Advisor

On March 18, 2014, PHMSA published HM-233C amending the Hazardous Materials Regulations to incorporate provisions contained in certain widely used or longstanding special permits and competent authority approvals; it also revises approval renewal requirements. Mr. Mazzullo reviews the amendments and associated comments giving detail on the substantive changes.


PHMSA Withdraws HM-247 Cargo Tank Motor Vehicle Loading/Unloading NPRM            

By Ed Mazzullo, Technical Advisor

PHMSA published a notice withdrawing a March 11, 2011 NPRM on February 25, 2014. In the NPRM, PHMSA had sought to reduce the risks associated with the loading and unloading of cargo tank motor vehicles used for the transport of hazardous materials. Mr. Mazzullo gives history of the NPRM, its proposed changes, and its possible future.




DOT Issues Special Permit Authorizing Electronic Shipping Papers     

By Frits Wybenga, Senior Technical Advisor

PHMSA issued special permit 15747 on December 30, 2013, allowing UPS Inc. to use electronic shipping papers in the transport of hazardous materials in its ground operations. While it could be the beginning of the widespread use of electronic shipping papers, questions remain about its efficacy. Mr. Wybenga provides his analysis.




Security Requirements for both DOT and TSA   

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

The first of a series of two articles, Mr. Pritchard’s report looks at security requirements as enforced by the U.S. Department of Transportation and the Transportation Security Administration. Among the discussed issues are components of a security plan, additional planning requirements, route selection, recordkeeping, and more.




ICAO Holds Multidisciplinary Meeting on Lithium Batteries     

By Frits Wybenga, Senior Technical Advisor

From February 4-6, 2014, ICAO convened a multidisciplinary meeting on lithium batteries at the FAA Test Center in Atlantic City, New Jersey. At this meeting, selected DGP members, and representatives from the FAA, the aircraft manufacturers, ICAO, the battery industry, and air carriers reviewed FAA test data, the ICAO safety systems methodology, and battery transport practices. Mr. Wybenga reports on their discussions and recommendations.




Marking the PSN and UN ID Number on an IBC      

By Ed Mazzullo, Technical Advisor

A questioner asks, “What are the size requirements for marking the proper shipping name and identification number on an intermediate bulk container?” This report examines the complexity of the question and provides some guidance.


OSHA Interpretations Provide Guidance for Complying with the Harmonized System of Classification Labeling Requirements       

By Ed Mazzullo, Technical Advisor

Mr. Mazzullo first looks at HCS 2012 Label Requirements and then reviews two letters of interpretation issued by OSHA since publication of the final rule providing guidance concerning the HCS 2012 labeling provisions. With certain exceptions, these provisions are mandatory after June 1, 2015.


OSHA Extends Comment Period on Process Safety Management Request for Information   

By Ed Mazzullo, Technical Advisor

In its Request for Information published on December 09, 2013, OSHA requested public input on potential revisions to its PSM standard, Explosives and Blasting Agents standard, other standards, and potential changes to PSM enforcement policies. On March 7, 2014, OSHA extended the deadline for submitting comments on its Request for Information to March 31, 2014. Read this report for background information




January a Busy Month for Rail Safety Initiatives 

By Ed Mazzullo, Technical Advisor

As government agencies in both the U.S. and Canada continued to pursue ways to enhance the safety of transporting crude by rail, a number of important actions and events took place early in 2014. This report summarizes Operation Safe Delivery: Enhancing the Safe Transport of Flammable Liquids; Operation Classification; recent NTSB recommendations; and actions from Transport Canada.


Transport Canada Rail Safety Rule Proposes Proof of Classification and Sampling Method Documentation         

By Ed Mazzullo, Technical Advisor

On January 11th, 2014, Transport Canada published a proposed amendment to improve the integrity of tank cars and enhance procedures for classification of dangerous goods. Certain provisions of the proposed amendment would apply to all modes of transport and shipping documents for all dangerous goods. Major provisions of the amendment are reviewed in this report.


DOT Emergency Restriction/Prohibition Order Expanded and Clarified        

By Ed Mazzullo, Technical Advisor     

On March 6, 2014, DOT issued an Amended Order which supersedes and replaces the one issued by the Secretary of Transportation on February 25, 2014. As with the original order, the Amended Order imposes restrictions effective immediately on the offering for transportation, classification, packaging, and transport of petroleum crude oil. Read to find out what remedial actions are required, for background information, and for significant changes from the previous Order.


DOT Takes Extraordinary Measures to Address Rail Safety in Petroleum Crude Shipments                      

By Glenn Wicks, Esq., Ronce Almond, Esq. and Arielle Pacer, Esq., The Wicks Group PLLC

The Wicks Group, PLLC, legal advisers to The Journal, looks at the recent emergency actions taken by DOT and the background of events. This article examines the legal authority of DOT to issue emergency orders and the compliance concerns addressed in recent orders.




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

  • Repair of IBCs
  • Definition of a friction-type closure
  • Periodic retesting of closure methods


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: January and February 2014. Thirty letters sorted, indexed and provided verbatim.          


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