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What You've Missed... January / February 2009 Issue

A sampling of what you've missed in the January / February 2009 issue of HAZMAT Packager & Shipper...

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

    about the new requirements designed to improve the safety of railroad tank cars transporting toxic inhalation hazard (TIH) materials.  These were published in the Federal Register on January 13, 2009 (see Hazardous Materials: Improving the Safety of Railroad Tank Car Transportation of Hazardous Materials, [Docket No. FRA–2006–25169]).  This is an executive summary of those requirements with observations by the author highlighting the major import of these changes.

    details about the comments PHMSA received regarding its Federal Register September 9, 2008, DOCKET HM-232F proposal to modify the current security plan requirements for the transportation of hazardous materials.  While the comments were generally supportive of the modifications made to the materials listing that would trigger the security plan requirements, they strongly objected to several changes to security plan rules or to required training elements.  The rulemaking also apparently presents serious problems for the special effects industry that support the television and movie industries, so much so that they purported these new rules would put these special effects operators out of business.

    about the final decisions by the UN covering the work the TDG Sub-Committee finalized during the 2007-2008 period.  These include a wide assortment of subjects covering limited quantities including consumer commodities, explosives, TIH liquids, harmonization of Class 8 with GHS, lithium batteries, portable tanks and IBCs.  The next series of changes to the DOT Hazardous Materials Regulations will reflect most these changes and become US DOT hazmat regulation.  Shippers and carriers particularly need to review this article so that they can be prepared.

    many details about what PHMSA has changed in the DOT hazardous materials regulations as a result of the Docket HM 224D/215J final rule publication.  These changes are mostly based on the revisions made in the 15th edition of the UN Model Regulations.  Especially helpful are comments by the author pointing out the several variances from the international requirements that DOT has introduced.

clarifying information about the confusion that surrounds the new ICAO/IATA text on EHS substances.  Are they subject to regulation?  When are they?  Does one treat EHS as regulated materials under the ICAO TI.  Between the US, the European and the IATA regulations very different considerations exist.  In addition, the lack of a DT/DF mark on some EPA hazardous substance or hazardous waste packages presents the potential for frustrating shipments.  The author provides many helpful clarifications about the situation that will help shippers and carriers address this issue.

about the confusion surrounding three PHMSA interpretation letters.  Problems in understanding the rules focus on two issues.   Can DOT Specification 51 and Specification IM101 and IM102 tanks for which new manufacture is no longer authorized continue to be used after January 1, 2010?  Are the T-Codes applicable to Specification 51 and to IMO portable tanks?   The author provides helpful guidance when addressing these two critical questions.

in a companion article about additional final decisions made by the UN Committee during the 2007-2008 period.  These cover a wide assortment of subjects including listing and classification, gases, classification of mixtures and solutions, electronic data interchange, desensitized explosives, radioactive materials, genetically modified organisms, transport units containing refrigerants of conditioners, substances evolving gases on contact with water and permeability of plastics packaging.  The next series of changes to the DOT Hazardous Materials Regulations will reflect these changes and become US DOT hazmat regulation.  Shippers and carriers need to review this article so that they can be prepared.

 
 
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