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The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 28, Number 5 January/February 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 November and December 2017 as well as January 2018.

  • Exception from “Different IBC Design Type” for Service Equipment
  • Shipping Description for a Flammable Liquid Reclassified Combustible Liquid
  • Transportation of Specification Cylinders prior to Requalification
  • Providing Emergency Response Information 
  • Classification of a Solution Not Capable of Sustaining Combustion 
  • Shipment of “Acetylene, Solvent Free” as a Gas Sample 
  • Criteria for Passing an IBC Drop Test

By Ed Mazzullo, Technical Advisor



Updates on PHMSA’s Regulatory Agenda: 2018    
By Ed Mazzullo, Technical Advisor 

Read this report to prepare for the coming year with Mr. Mazzullo’s succinct summary of the Fall 2017 Unified Agenda of Regulatory and Deregulatory Actions. Presented is the administration’s emphasis on reducing regulations, PHMSA’s priorities, and closes with PHMSA’s regulatory schedule.

Questions for PHMSA and Responses 
From The Journal

PHMSA provides readers of The Journal with official responses to our questions on: PHMSA policy and rulemaking; rulemaking timelines; enforcement; and special permits


Clarification of IBC Inquiries: Hazcom, Reuse, and Employer Responsibilities  
By Ed Mazzullo, Technical Advisor

Mr. Mazzullo draws upon his extensive knowledge to respond to reader concerns on the topics of hazard communication for intermediate bulk containers (IBCs), reuse of certain IBCs, and a hazmat employer’s responsibilities regarding hazmat training. Read for essential advice and references.


FMCSA Proposes Changes to HOS Guidance on Use of a Commercial Motor Vehicle for Personal Conveyance      By Ed Mazzullo, Technical Advisor 

On December 19, 2017, the Federal Motor Carrier Safety Administration (FMCSA) published a notice requesting public comments on proposed changes to hours-of-service regulatory guidance concerning driving a commercial motor vehicle for personal use while “off-duty.” This report takes a look at the history of FMCSA guidance on this subject and potential effects of the proposed changes particularly from a hazmat transportation perspective.


Several Reader Questions Regarding Lithium Batteries       
By Frits Wybenga, Senior Technical Advisor

Mr. Wybenga addresses several questions about cell construction type to distinguishing between single and multi-cell batteries.



“Risky Trains” Routing Legislation Introduced        
By Cynthia Hilton, Legislative Advisor

The recent U.S. DOT decision to rescind Pipeline and Hazardous Materials Safety Administration (PHMSA) requirements for the installation and use of Electronically Controlled Pneumatic (ECP) braking systems on “high-hazard flammable unit trains” has led to the introduction of H.R. 4629, the “Save Our Communities from Risky Trains Act.” Ms. Hilton reports on background of the ECP requirements; their subsequent withdrawal; and the current legislation seeking to codify voluntary routing practices of railroads carrying named security-sensitive hazardous materials.

Lac-Mégantic: Legal Consequences        
By JHMT Staff

A brief update following the verdicts for some defendants charged in the fatal derailment of July 2013. Future cases are pending.



Report on 52nd Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods                
By Frits Wybenga, Senior Technical Advisor

Mr. Wybenga provides his report on the 52nd session of the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (SCETDG), held from November 27 – December 6, 2017 in Geneva, Switzerland. This was the second session of the new biennium. Changes to the UN Model Regulations (UNMR) agreed at all four sessions of this biennium will form the basis for amendments included in the 21st revised edition. His report is divided into categories for readers’ convenience.


Deciding Who Should Lead U.S. Policy for Air Transport of Hazardous Materials   
By Cynthia Hilton, Legislative Advisor

The push and pull continues between the Pipeline and Hazardous Materials Safety Administration and the Federal Aviation Administration over which agency should be lead delegate to the US at meetings of the ICAO DGP. This report takes a look at actions taken as well as what is to come.

DGP 26 - What’s in store in the 2019-2020 Edition of the ICAO TI     
By Frits Wybenga, Senior Technical Advisor

The 2019-2020 edition of the International Civil Aviation Organization’s Technical Instructions (ICAO TI) becomes effective on 1 January 2019. Mr. Wybenga provides this report highlighting the significant discussion and decisions made at the most recent 26th session of the ICAO Dangerous Goods Panel. Finalized revisions by the DGP will be included in the next ICAO TI.

IATA Introduces 59th DGR - Effective January 1, 2018       
By Frits Wybenga, Senior Technical Advisor

The 59th Edition of the International Aviation Transport Association's Dangerous Goods Rules (IATA DGR) became effective on January 1, 2018. Changes introduced in the 59th edition are for the most part limited to changes incorporating two addenda to the ICAO TI as well as clarifications to the DGR 58th edition. IATA has issued a document summarizing the changes introduced in the latest edition and Senior Technical Advisor Frits Wybenga provides this report reviewing the newest IATA DGR.



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

  • Reuse of packagings
  • Closure securement by secondary means for packagings for liquids in air transport
  • Definition of aerosol


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: November through December 2017, January 2018. 22 letters sorted, indexed and provided verbatim.      

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