As a Subscriber, you would have learned ....

that DOT does not accept a “one size fits all” approach for hazardous materials security plans for various facilities operated by the same company. DOT states that each facility “should” have a security plan tailored to the specific hazardous materials handled at the facility, to the physical characteristics of the facility, and to the operational procedures in place at the facility.

that in Docket 215I, DOT proposes amendments to the rules covering shipping papers. The most significant of these is an amendment to require use of the UN-number-first sequence (currently allowed as an option) for the basic description of hazardous materials on shipping papers. Obviously, this will have extremely broad implications throughout the hazardous materials transportation and emergency response community. Companies will need to prepare.

that DOT points out in the matter of aerosols imported in ICAO/IATA “IP” type aerosol containers, that these are not the same as the DOT specification 2P or 2Q containers that may be required under the HMR. In order to be eligible for reshipment, i.e., distribution in United States, the ICAO/IATA “IP” type aerosols must meet the relevant DOT specification at the time of manufacture. This DOT observation might pose a significant obstacle for some companies to international distribution of products.

that a major PHMSA initiative in Docket HM-231 is to distinguish between the terms “bulk packaging” and “non-bulk packaging”. PHMSA claims they are not changing the meaning of the terms - only clarifying. The author questions that this is mere clarification.

that in Docket 215I, DOT proposes a change to § 178.274 that would require new UN portable tank design types subject to the requirement for rail impact testing, to be tested according to the impact test procedure prescribed in Section 40 of the UN Manual of Tests and Criteria.

that in Docket 215I, DOT proposes a very significant change to the current oral toxicity threshold that is used to determine if one is subject to regulation as a poison of Class 6.1. If adopted, some materials (solids) that are not regulated would be regulated under Packing Group III, whereas other materials (liquids) currently regulated in that packing group would no longer be regulated. In addition, some materials currently regulated in Packing Group I or II would be assigned to a different packing group.

that a new category of packaging called Large Packaging, is proposed to be introduced into the DOT Hazardous Materials Regulations for the first time. Readers will want to understand the implications more clearly.

that the international UN GHS developments coming soon will introduce a number of new standard hazard criteria that will have impacts across many areas of regulation beyond just transportation.

that the UN Subcommittee on the Transport of Dangerous Goods has provisionally adopted new requirements for the target surface used in conducting the drop tests for UN packagings, IBCs, Large Packagings, and Infectious Substances packagings. If left to stand these new standards could pose serious problems for those who test UN/DOT packagings, including those who self-certify their packagings as meeting these performance requirements.

that in Docket HM-218D transportation and documentation rules for marine pollutants in non-bulk packaging now authorized to be transported as non-hazardous, could become more restrictive. Of particular concern might be the materials moving inland from a port to destination after having completed transportation by vessel.