Thursday, May 24, 2018
Text Size

Current Issue

The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 28, Number 6 March/April 2018

In This Issue

PHMSA Penalties: November and December         

Compliance Dates: Also go to for this file, containing links to official documents and our reports. 


A Review and Summary of Prominent Recent Letters of Interpretation

A Summary Review of Recent and Important DOT Letters of Interpretation of the Hazardous Materials Regulations from January and February 2018.

  • De Minimis Exceptions for Division 6.1, PG 1 Materials 
  • Pressure Relief Devices on DOT 2P and 2Q Containers for Butane 
  • Hazmat Training for Shipments from A Foreign Location 
  • Packaging a Prototype Lithium Battery Contained in Equipment 
  • Hazard Communication for Explosives in a Combination Motor Vehicle 
  • Exceptions for RCRA Empty Packagings 
  • Shipment of Lighters by Private Carrier 
  • Regulation of Drilling Mud as a Radioactive Material 
  • Service Equipment for UN Composite Cylinders 

By Ed Mazzullo, Technical Advisor




Funding PHMSA’s Hazardous Materials Transportation Program – FY 201924-29
By Cynthia Hilton, Legislative Advisor

In the interim between pending outcome of the fiscal year (FY) 2018 process, the FY 2019 cycle has kicked off with the release of the President’s budget request (BR). This report provides information on the Bipartisan Budget Act of 2018, PHMSA’s FY 2019 BR, PHMSA’s operational expenses, emergency preparedness grants, and finishes by looking at the adequacy of the budget request in context of the current day.



Do Function-Specific and Recurrent Training Provisions Apply to Registered Inspectors of Cargo Tanks?   
By Ed Mazzullo, Technical Advisor

Mr. Mazzullo responds to a hazmat employer wondering if the qualifications necessary to be a registered inspector, on top of the requirements to periodically recertify, that the provisions for function-specific retraining might not apply to registered inspectors. However, a reading of the HMR for training of hazmat employees suggests otherwise.



Filling and Use of a Foreign-Manufactured Packaging in the U.S. 
By Ed Mazzullo, Technical Advisor

A company intends to import UN 4G combination packagings manufactured by an affiliate in Canada which are to be filled and offered for transport in the US and asks about applicable Canada-US reciprocity provisions. This report covers that question as well as periodic testing requirements.



Flammable Goods Drop Shipped to South America 
By Frits Wybenga, Senior Technical Advisor

Presented with a question about drop shipments of flammable goods to South America, Mr. Wybenga examines the hazmat and commercial aspects of the question. He examines the requirements of contract provisions, looking at “Incoterms” - commercial contractual rules governing freight transport used in sales contracts involving importing and exporting.



Shipper - Carrier Issues Regarding Polymerizing Substances  
By Frits Wybenga, Senior Technical Advisor

This report reviews the applicable requirements of the IMDG code for carriers concerned with safely transporting substances that could polymerize. Read for information on the background of regulations of polymerizing substances, stabilization, and shipping frustrations.

Segregation of Hazardous Materials: A Look at a DOT Letter of Interpretation 
By Frits Wybenga, Senior Technical Advisor

Focusing on a particular question in a series raised pertaining to segregation of incompatible materials, this report takes a deep look at the requirements in §177.848: compatibility of mixed contents; inner and outer packagings; and highway transport.



House Transportation and Infrastructure Committee Announces Its Plans for FY 2019  
By Cynthia Hilton, Legislative Advisor

Standing committees of each chamber of US Congress are required to submit their “Views and Estimates” (V&E) to their respective Budget Committees; on February 13, 2018, the House Transportation and Infrastructure Committee met in executive session to, among other things, approve the Committee’s V&E for FY 2019. This short read reports on the legislative priorities stated by the Committee.



Exceptions For “Empty” Packagings Containing the Residues of Hazardous Materials
By Ed Mazzullo, Technical Advisor

Mr. Mazzullo takes a close look at §173.29: Empty packagings to address a delicate question regarding the transportation of packagings containing hazardous material residue.



Marking and Placarding a Cargo Transport Unit Containing Packaged Flammable Liquids for Export   
By Ed Mazzullo, Technical Advisor

What marking and labeling are required for a 40 foot cargo transport unit transport from the U.S. to Germany, containing 25,000 pounds of Class 3 Materials and an unspecified quantity of other Class 3 Materials packaged as a Limited Quantity? This report provides an opinion on the applicable IMDG Code requirements.



RID/ADR/ADN Joint Meeting Pre-Meeting Summary: Spring 2018 
Prepared by JHMT Staff and Reviewed by Senior Technical Advisor Frits Wybenga

The RID Committee of Experts and the Working Party on the Transport of Dangerous Goods (RID Committee; WP.15) will hold their next Joint Meeting on March 12-16, 2018, in Bern, Switzerland. Amendments will be discussed to the European Agreement concerning the Regulation concerning the International Carriage of Dangerous Goods by Rail (RID); the International Carriage of Dangerous Goods by Road (ADR); and the European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN).

IMO Update: Changes to the IMDG Code       
By Ed Mazzullo, Technical Advisor                        

This report provides information on amendments incorporated into the newly-mandatory IMDG Code Amendment 38-16the body of which harmonize with the UN Model Regulations. Amendment 39-18 will be finalized once approved in May of this year, and expected changes are included.


Testimony on Lithium Batteries & Undeclared HazMat Shipments      
By Cynthia Hilton, Legislative Advisor

Ms. Hilton provides this report on the February 27, 2018, hearing on “The State of Aviation Safety” before the Aviation Subcommittee of the House Transportation and Infrastructure Committee. Discussed were ICAO standards, the FAA Modernization and Reform Act, and undeclared hazmat shipments.



The Journal of HazMat Transportation’s Exclusive Comments on the U.S. DOT Letters of the Hazardous Materials Regulations  

By Frits Wybenga, Senior Technical Advisor

  • Transport of nonspillable batteries by passengers and crew as part of mobility aids
  • Reduced design margin for UN portable tanks


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: January and February 2018. 15 letters sorted, indexed and provided verbatim.          

Copyright 2018, PRI International, Inc. All Rights Reserved.

The Journal of HazMat Transportation and its Digital Edition is published bi-monthly and HazMat Alerts are issued severally per month by PRI International, Inc. Subscription licensing inquiries and letters to The Journal of HazMat Transportation should be directed to PRI International, Inc., P.O. Box 3144, West Chester, PA 19381-3144, tel. (610) 436-8292, or fax (610) 436-9422. E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

IMPORTANT NOTICE: Reproduction in part or whole, or the derivation of content for external or internal redistribution via print, facsimile, electronic, or any other means, of content presented in The Journal of HazMat Transportation (print and digital) editions, HazMat Compliance Alerts, The HazMat Reference Gateway™, and The HazMat Compliance DataBase™  is prohibited without explicit prior written permission from the publisher (see Title 17 USC),  or unless commercial arrangements have been made via subscription license, available to all subscribers. Violators may be subject to fees by PRI International, Inc.  PRI International, Inc. will enforce its intellectual property rights to the fullest extent provided by United States and International law against all violators.

Single user content licensing and multiple user agreements are available which provide for rights to the internal distribution of content. Call (610) 436-8292 for information.  Complete intellectual property provisions and guidelines for use are found at

PRI International, Inc. hereby disclaims responsibility for any statements made or opinions expressed in its publications by individual or group contributors.