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Current Issue

The Journal of HazMat Transportation

A Publication of PRI International, Inc.

 

Volume 27, Number 4 November/December 2016

In This Issue 1

 

PHMSA Penalties:  September and October 2016                  

RULEMAKING ACTIVITY

Summary of U.S. D.O.T. Rule & Rulemaking Activity

Also go to www.hazmatship.com, Critical Dates. Summaries are linked to our reports and Federal Register notices, and go back several years.

Compliance Dates:   (Newly Updated. Also go to www.hazmatship.com for this file, containing links to official documents and our reports.

 

HAZMAT TRANSPORTATION GUIDANCE

A Summary Review of Recent and Important DOT Letters of Interpretation of the Hazardous Materials Regulations from September and October 2016.

  • Retention Requirement for Manufacturer’s Notification for a Non-Bulk Packaging     
  • Loading and Securing Palletized Materials   
  • Applicability of “Hazmat Employee” Definition to Data Entry Personnel             
  • Storage of Tank Cars Containing Class 3 Flammable Liquids    
  • Non-Specification Packaging Exceptions for Wet Lead Acid Batteries     
  • Use of a Placard Intended for an ID Number without the ID Number Displayed 

By Ed Mazzullo, Technical Advisor

 

DANGEROUS GOODS BY RAIL

ECP Brake Concerns  
By Edward W. Pritchard, Senior Partner, Paladin Consulting Group

Mr. Pritchard continues his reporting on the effects of Final Rule HM-251. Here the focus is on electronically controlled pneumatic (ECP) brakes, required for rail carriers operating high-hazard flammable trains. The Government Accountability Office issued a report last month with recommendations for DOT to reevaluate its analysis of ECP brakes. Mr. Pritchard takes a look at those recommendations and DOT’s response.

 

DANGEROUS GOODS PACKAGING

Definition of a Competent Authority Approval and Use of Plastic Packagings Beyond Five Years       
By Frits Wybenga. Senior Technical Advisor                     

Mr. Wybenga examines two letters of interpretation issued by PHMSA to address questions regarding plastic packagings produced more than 5 years ago as well as the issue of when the HMR constitutes a competent authority approval.

 

REVERSE LOGISTICS

PHMSA Provides The Journal a Clarification on Reverse Logistics 
By Frits Wybenga. Senior Technical Advisor

Following to The Journal’s discussion of interpretation 16-0057 in the July/August 2016 issue, The Journal sought PHMSA’s confirmation of our understanding of Reverse Logistics requirements in a letter that PHMSA responded to with interpretation letter 16-0158, dated October 11, 2016. Mr. Wybenga continues his review of the subject. Our originating letter as well as letter 16-0158 are included following his report.

 

BULK PACKAGING

PHMSA Requests Public Comments on Amending Identification Number Exceptions for Fuels Transported by Cargo Tank      
By Ed Mazzullo, Technical Advisor

This report examines the HM-213E ANPRM and two petitions to it in turn. PHMSA published in the Federal Register Docket No. PHMSA–2016–0079 (HM–213E) as required by a provision in the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016 .

 

Q&A

Viscous Flammable Liquids and Open-Head Plastic Pails  
By Ed Mazzullo, Technical Advisor

Mr. Mazzullo responds to a reader’s inquiry with helpful information regarding the classification of viscous flammable liquids as well as the suitability of using an open-head plastic pail for air transportation.

 

UN Reports

Pre-Meeting Report on Proposals to be Discussed at the 50th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods      
Compiled by JHMT Staff and Reviewed with Comments from Frits Wybenga, Senior Technical Advisor

From November 28 to December 6, 2016, the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (SCETDG) will hold its 50th session in Geneva, Switzerland, addressing 37 formal proposals as well as several informal papers. This is the fourth and final session of the biennium and changes to the UN Model Regulations agreed at all four sessions of this biennium will form the basis for amendments included in the 20th revised edition. Read to find out what is likely to be decided at the meeting and subsequently incorporated in international and domestic regulations.

Pre-Meeting Report on Proposals to be Discussed at the 32nd Session of the UN Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals 
Compiled by JHMT Staff and Reviewed with Comments from Frits Wybenga, Senior Technical Advisor

From December 7 to 9, 2016, the United Nations Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (SCGHS) will hold its 32nd session in Geneva, Switzerland, addressing 11 formal proposals as well as informal papers. Read for a review and summary of papers to be discussed.

 

CANADIAN RULES AND REGULATIONS

Update on Canadian Transport of Dangerous Goods Regulatory Activities   
By Ed Mazzullo, Technical Advisor 

Read this report for Mr. Mazzullo’s look at recent actions by Transport Canada’s Transport of Dangerous Goods Directorate (TDG), including proposed and completed changes to the TDG Regulations and protective directions, as well as some of the safety advisories issued this year.

 

GOVERNMENT OVERSIGHT

OIG Audit Calls for Process Changes for PHMSA 
By Ed Mazzullo, Technical Advisor 

The Office of the Inspector General (OIG) of the Department of Transportation released a report last month reviewing PHMSA’s responsiveness to congressional mandates and recommendations. Mr. Mazzullo summarizes OIG’s findings and subsequent recommendations, as well as PHMSA’s response to the OIG.

 

COMMENTS ON DOT INTERPRETATIONS   

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

  • Label size requirements
  • Transport of rail tank cars containing flammable liquids to private track
  • Classification of aerosols

U.S. DOT INTERPRETATIONS OF THE HMR      

U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: September and October. 18 letters sorted, indexed and provided verbatim.

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