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Contents Pages : Volume 20, Number 5 January/February 2010In This Issue
Summary of
PHMSA PENALTY VIOLATIONS: U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: November and December 2009. Forty-two letters sorted, indexed and provided verbatim. HAZMAT TRANSPORTATION GUIDANCE Is a separate test required for inner receptacles of combination packagings that are intended to contain both liquid and solids? Is an incident involving a leak from a customer's piping or storage tank that occurs during the time a hazardous material is unloaded from a cargo tank motor vehicle into a storage tank, required to be reported? Do cylinders that have a contained pressure below 29 psig (40 psia), have to comply with Docket HM-224B final rule? Why are CT numbers given to so many companies who obviously do not have the qualifications to perform the work outlined under the DOT cargo tank rules? Are used or spent batteries of the type "Batteries, dry, sealed, n.o.s." with a marked rating of 9-volt or less that are combined in the same package and transported by highway or rail for recycling, reconditioning, or disposal, subject to the HMR? UN DECISIONSSummary of the Results of the UN Sub-Committee of Experts 36th Session By Frits Wybenga, Senior Technical Advisor The UN Sub-Committee of Experts on the Transport of Dangerous Goods held its 36th session from 30 November to 9 December in Geneva. This was the second of four meetings that will be held during the 2009 – 2010 biennium which should result in the 17th revised edition of the UN Model Regulation. In this report Mr. Wybenga discusses Chairmanship, small quantity exceptions- De minimus, adhesives under pressure, flexible bulk containers, location of the word “waste” in the basic description, and class 8. HAZMAT SECURITY CFATS Corporate Reporting Tool: Tracking the Status of Multiple Facilities By Patrick Coyle The Infrastructure Security Compliance Division of DHS has been working on a pilot tool to allow easier corporate management of the implementation of the CFATS regulations across multiple facilities. This tool allows a corporate security officer or regulatory compliance officer to track the CFATS status of multiple facilities within the corporation from a single secure web site. In this report Mr. Coyle the problem of CFATS and why the pilot tool will be a solution. CARGO SECUREMENT U.S. Coast Guard Seeks Comments on Methods of Cargo Securement On January 8th the US Coast Guard (USCG) posted a request for comments in the Federal Register concerning methods for securing cargo in transport vehicles and freight containers to determine if there is a need for improved performance criteria for flexible strapping securing systems, or if there is a need for standardized approval or certification process for such securing systems. This report looks at the problems and the potential solution as well as specific questions that the Coast Guard is requesting comments for. Also included in the report is a letter to The Journal on securement from Capt. Philip I. Anderson Chief, Technical Department of National Cargo Bureau, Inc. DOT RULEMAKINGS HM-215K – Implementation of Changes to the 49CFR Based on the 16th Edition of the UN Model Regulations By Frits Wybenga, Senior Technical Advisor PHMSA issued an HM-215K Advanced Notice of Proposed Rulemaking on October 21, 2009, asking for comments on how they should implement changes introduced in the 16th revised edition to the UN Model Regulations as well as newly introduced changes to the upcoming editions of the ICAO Technical Instructions the IMDG Code. In this report Mr. Wybenga looks at the NPRM and issues that may occur with sour crude, classification of explosives, IBC rebottling, limited quantities, metal-hydride storage systems in conveyances, and in vitro testing for corrosivity. Public Comments on PHMSA’s Advanced Notice of Proposed Rulemaking: HM-215K By Patrick Coyle This report looks at the comments that were submitted on HM-215K regarding general harmonization issues, classification of explosives, limited quantity system, classification of sour crude, IBC rebottling, in vitro testing for corrosivity. SPECIAL PERMITS PHMSA Develops Standard Operating Procedures for Special Permits By Frits Wybenga, Senior Technical Advisor In response to criticisms from the DOT Inspector General’s Office and from the House Committee on Transportation and Infrastructure, PHMSA has developed Standard Operating Procedures for processing applications for Special Permits. In this report Mr. Wybenga explains the standard operation procedures for special permits. HAZMAT Q&A Classification Implications for Solutions Taking the New Environmentally Hazardous Substance Criteria into Account This report consists of a Q&A regarding if a component is named a dangerous substance under the IMDG Code, and the other component is found to be environmentally hazardous, how should the solution be reclassified? HAZMAT COMPLIANCE Handling an Out of Compliance Hazardous Materials Shipment By John Gillick, Esq. In this report, John Gillick addresses the question of the carrier’s role in the identification of an out-of-compliance shipment of a hazard material, and details associated with the refusal of that shipment assuming that the carrier identifies the shipment as problematic. Failure to do so could result in penalization of both the shipper and carrier with serious financial consequences. The author also provides a comprehensive review of the HMR’s incident reporting requirements. LITHIUM BATTERIES HM-224F: The Lithium Battery Notice of Proposed Rulemaking By Frits Wybenga, Senior Technical Advisor PHMSA’s January 11 NPRM on lithium batteries is the one of the most significant rulemakings issued in recent years, according to the author. While all modes of transportation stand to be affected, the air mode is most significantly impacted by the proposed rules. In this report, inconsistencies between the international provisions and those proposed for the U.S. HMR are discussed including elimination of the small battery exception for the air mode. The matter of packaging design type changes and the need for retesting is addressed along with other implications of the NPRM. COMMENTS ON DOT INTERPRETATIONS
Comments on Significant Letters of Interpretation of the HMR
Copyright 2010 by Packaging Research International, Inc. All Rights Reserved.
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