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Recent Issue Summaries

What You've Missed... May / June 2008 Issue

A sampling of what you've missed in the March / April 2008 issue of HAZMAT Packager & Shipper...

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

that the June 30th to July 9th 2008 UN Transport of Dangerous Goods Sub-Committee (TDG) has a number of important items on its agenda.  Highlights of the meeting are covered in this article. It provides information about changes being considered.  Such articles are important to keep ahead of UN developments and to permit timely communications with DOT representatives attending the meeting.  UN TDG Sub-Committee Considers Amendments to UN Model Regulations

    how consignees can incur compliance responsibilities under the DOT Hazardous Materials Regulations.  Normally consignees are not the target of the DOT hazmat regulations.  However, by performing certain actions, consignees can definitely become obligated to compliance with the rules, the same as a packaging manufacturer, a shipper or a carrier.  Commentaries on DOT Letters of Clarification

    that the holder of a special permit is obligated to specially train employees in meeting the extra conditions and requirements typically spelled out in a special permit.  Do you know that this training is required in addition to the training requirements imposed for the 49 CFR textual materials?  The author finds that such training is often overlooked by companies holding special permits.  These “special” DOT hazardous materials training requirements are typically set forth in the boiler plate of most special permits.    Commentaries on DOT Letters of Clarification

    that the most daunting task associated with implementing the recent IMDG EHS amendments will be to evaluate large numbers of substances and mixtures currently regulated as hazardous materials.  Required to be included in this review as well, are substances and mixtures not currently subject to dangerous goods regulations.    In this first of two articles, the author comprehensively examines the classification criteria and how they apply to substances.   New IMDG Code Criteria for Classifying Environmentally Hazardous Substances

    how to sort out the US DOT and IMDG requirements for domestic and international shipment of combustible liquids when they are marine pollutants.  The rules are confusing but the author brings some order to the thought process that must be followed to assure compliance with the hazmat regulations.  This article is particularly pertinent in view of some new Docket HM-218D changes.  Question and Answer on Combustible liquids in International traffic

about the new EU chemicals policy known as REACH (Registration, Evaluation and Authorization of CHemicals). REACH applies not only to chemical companies but to any business which uses chemicals and sells to the European Union (EU).  REACH is a new European Community regulation on chemicals and their safe use. It deals with the Registration (by industry), Evaluation (by the authorities), Authorization and possible restriction (by the authorities) of CHemical substances. The new European REACH regulation entered into force on 1 June 2007 and is in the process of being implemented.  The New European REACH Regulations

    how a company might address the DOT closure notification problem.  Might
the Internet and company Intranets be the solution.  The author provides
some ideas on how this difficult DOT requirement can be addressed in today's
electronic age. The Use of Electronic Information Communication to Satisfy Closure Notification Requirements under the Hazardous Materials Regulations

that DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) recently proposed to require bulk shipments of Poison Inhalation Hazard (PIH) materials, such as chlorine and anhydrous ammonia, to meet new safety standards.  The chemical industry is bridling at the proposed tank car design changes, which are still hypothetical and untested.  This is because ultimately they and their customers will bear the considerable expense of these new tank cars.  Further complicating matters, manufacturers of rail cars are apparently not ready to initiate prototype testing and production of the proposed cars.  The author poses 5 interesting questions to the FRA Administrator.  Federal Railroad Administration Challenged -- New Regulations Proposed

    that the recent failure of an aluminum cylinder containing ethyl chloride would seem to have little impact on rules for assigning proper shipping names to mixtures of dangerous goods, until one considers some of the circumstances.  To assure safety in transportation, understand why the naming of mixtures containing two or more dangerous goods may need to be based on the properties of the mixture and not, as it is today, on the individual substances.   A Cylinder Incident Prompts Discussion on Assigning Proper Shipping Names to Mixtures