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

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

    about the HR 2868 legislation, a codification of the requirements for protecting high-risk chemical facilities from the risk of terrorist attack. Almost 7,000 high-risk chemical facilities around the country are in the process of updating their facility security plans to meet the standards set forth in the Chemical Facility Anti-Terrorism Standards (6 CFR part 27) (CFATS).  This bill will affect many more facilities than the current CFATS regulations.  Hazmat Security -- Chemical Facility Anti-Terrorism Act of 2009.

About the results of the UN Transport of Dangerous Goods Subcommittee that met during the week of June 22, 2009.  This was the first of four subcommittee meetings that will lead to the issuance of the 17th edition of the UN Model Regulations.  The Subcommittee made some decisions affecting the hazmat industry and it is apparent that other issues will bear close watching.  The author gives a rundown on what has already been decided, followed by a brief description of items that need to be followed. Outcome of the UN TDG Subcommittee 35th Session.

about a new tool the DHS Infrastructure Security Compliance Division (ISCD) has recently added.  The Chemical Facility Anti-Terrorism Standards (CFATS) implementation is currently in its most complicated phase, the submission of Site Security Plans (SSP).  With the complexity of the SSP submission process, high-risk chemical facility personnel need assistance.   Visit a new web page that helps facilities.  Hazmat Security -- CFATS Compliance Assistance Visits.

that in an early move to amend the Hazmat Law for reauthorization, the House has proposed changes to the existing law.  A concern is that HMTA reauthorization will get little attention as it moves forward.  Read this helpful synopsis of what hazmat changes are introduced and about industry concerns not being taken into account.  In several areas, including lithium batteries, it could make what should be “regulatory” requirements into “law”.  The Interested Parties White Paper is also presented. House Markup of the Hazmat Transportation Law.

about a new Senate Bill S 1385, the Maritime Hazardous Cargo Security Act (MHCSA) of 2009. The bill is “to protect America’s communities and economy by improving the security of hazardous cargo shipments, including liquefied natural gas (LNG) and liquefied petroleum gas”. Actually, the proposed legislation covers much more than LNG and LPG shipments. It creates a new class of hazardous materials called Especially Hazardous Cargo (EHC).  EHC means anhydrous ammonia, ammonium nitrate, chlorine, liquefied natural gas, liquefied petroleum gas, and any other substance or materials identified as an especially hazardous cargo by the Secretary of the Department of Homeland Security.  Maritime Hazardous Cargo Security Act of 2009.

about PHMSA’s announcement that registration with AAR and payment of a fee in association with the AAR 600 regulations and the former standard, is no longer a necessary element of compliance with AAR 600.  Commentaries on DOT Interpretation Letters.  

that the Pipeline and Hazardous Materials Safety Administration (PHMSA) recently published, on its website, a Guide to Developing a Hazardous Materials Training Program.  The author describes its contents and suggests how the guide could become even more useful.  The guide is to help hazmat employers “determine what type of training and training environment may be best for their employees”.  A Review of PHMSA’s Hazmat Training Program Guide.

that recently the Chemical Safety Board published an advance notice of proposed rulemaking (ANPRM) covering the reporting of accidental chemical releases . Because spills “in the air” are already required for hazardous materials under DOT transportation regulations, companies need to watch carefully for duplicative overlap in incident reporting.  Such efforts need to be coordinated to avoid unnecessary layering of incident reporting requirements.  Comments are needed from the transportation industry.  Incident Reporting -- Chemical Safety Board Spill Reporting,.

about important background to the process started earlier this year whereby high-risk chemical facilities began submitting site security plans (SSP) to DHS as part of the Chemical Facility Anti-Terrorism Standards (CFATS) program. One of the areas required to be addressed in that SSP is the performance of “appropriate background checks and  [ensuring] appropriate credentials for facility personnel”.   Hazmat Security -- CFATS Personnel Surety Program.