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The Journal of HazMat Transportation

A Publication of PRI International, Inc.

Volume 25, Number 2 July/August 2014


In This Issue 1


Summary of U.S. D.O.T. Rule & Rulemaking Activity     46-48

(Also go to www., Critical Dates)


Compliance Dates:  For a summary of important international and U.S. compliance dates, go to, Compliance Dates.  Summaries are linked to our reports and Federal Register notices.






A Summary Review of Recent and Important DOT Letters of Interpretation of the Hazardous Materials Regulations from May and June 2014.

By Ed Mazzullo, Technical Advisor

  • Oil Spill Prevention and Response Plans              8
  • Transport of Prototype Lithium Batteries by Vessel       11
  • Sufficiency of an ICAO Competent Authority Approval from Country of Origin     15
  • Lithium Ion Battery Powered Wheelchair as Checked Baggage           17
  • Definition of Residue          23
  • Identification Numbers on an IBC on a Flatbed Truck  24
  • Empty Packaging Containing the Residue of a Limited Quantity         27
  • Removal and Reinstatement of Packing Instruction US 1 for Oil Well Perforating Guns      35
  • Weep Hole in the Outer Steel Drum of a Composite Packaging 39



Report on the 45th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods             9-13

By Frits Wybenga, Senior Technical Advisor

In his report on the third meeting of the biennium, Mr. Wybenga takes a look at what was decided and what was held until the next meeting. Of particular interest to some readers may be the concerns raised over crude oil; further discussion regarding lithium batteries; harmonization of corrosivity criteria with the GHS and the possible impact on packing group designations for a large number of Class 8 materials; in addition to other pressing subjects.



Transport Canada Adopts Two Series of Amendments to its TDG Regulations and Proposes New Tank Car Requirements for Pre-Consultation    31-35

By Jean-Pierre Gagnon

Transport Canada published two final sets of amendments to its TDG Regulations on July 2, 2014. These amendments contain hundreds of changes, some with significant impact on stakeholders. Mr. Gagnon provides a thorough and detailed look at the most noticeable of these changes, affecting safety marks, update of standards, rail requirements, and the phasing out of older cars and performance requirements.



Understanding the Elements, Application, and Importance of Hazardous Material Transportation Security Plans            18-21

By The Wicks Group, PLLC

The Hazardous Materials Regulations requires persons offering for transport or transporting certain hazardous materials in commerce to develop and implement security plans. Read this report to understand when a security plan is required, what are its elements, and what is required for format and revision.



Dangerous Goods Training: The Critical Components to an Effective Safety Program           14-17

By Geoff Leach, Director of the Dangerous Goods Office Limited

Mr. Leach draws on his experience as an overseer of the UK’s Civil Aviation Authority Dangerous Goods Training Approval Scheme to produce a thorough article on how to avoid common instructional pitfalls, a discussion of technical issues, as well as suggestions for engaging an audience.



PHMSA Issues Safety Advisory on Unauthorized Compressed Gas Cylinders 22-23

By Ed Mazzullo, Technical Advisor

On July 3, 2014, PHMSA published a safety advisory notice concerning compressed gas cylinders improperly marked as complying with the HMR  by Always Safe Fire Extinguisher and Safety, LLC, which has never been approved by PHMSA to either requalify or mark DOT-specification or special permit cylinders as being requalified.



PHMSA Proposes Adoption into HMR of Provisions for Bulk Vehicles Used for Explosives under Special Permits          22-23

By Ed Mazzullo, Technical Advisor

PHMSA published a notice of proposed rulemaking proposing changes to the HMR on July 15, 2014 to provide for the transport of certain explosives and other hazardous materials in specialized bulk packagings not otherwise authorized under the HMR and to incorporate by reference an Institute of Makers of Explosives safety standard which provides recommendations for the safe transportation of explosives and other hazardous materials transported in multipurpose bulk trucks.Read this report for more on provisions of the proposed rule.



FMCSA Issues Updated National Hazardous Materials Route Registry 24

By Ed Mazzullo, Technical Advisor

On July 14, 2014, the Federal Motor Carrier Safety Administration (FMCSA) published an update to the National Hazardous Materials Route Registry, a listing of all designated and restricted road and highway routes for highway route controlled quantities of Class 7 (radioactive) materials and non-radioactive hazardous materials transported by motor vehicle in types and quantities which require placarding. FMCSA requests comments on the points found in this report.



Reporting of Non-Accident Releases           7-8

By Edward W. Pritchard, Senior Partner, Paladin Consulting Group

Under §171.16, PHMSA requires a detailed hazardous materials incident report for non-accident releases (consisting of leaks, splashes, and other releases from improperly secured or defective valves, fittings, and tank shells, and also including venting of non-atmospheric gases from safety relief devices). This article looks at the information collected, how it is shared, and how NARs affect industry.


U.S. DOT Announces Proposed Rulemakings for High Hazard Flammable Materials Transported by Rail     30

By Ed Mazzullo, Technical Advisor

The US Secretary of Transportation announced on July 23, 2014, the details of two proposed rulemakings to address the risks posed by petroleum crude oil, ethanol, and similar Class 3 flammable liquids transported in large volume by trains. HM-251 proposes new operational requirements for HHMTs, improvements in tank car standards, and revision of the general requirements to ensure proper classification and characterization of mined gases and liquids. HM-251B is an ANPRM seeking comment on expanding the applicability of comprehensive oil spill response to lower thresholds. Read this for a summary of proposed changes.



An Exposition on HM-250: Compatibility With the Regulations of the International Atomic Energy Agency           36-45

By Wade Winters, CEO, Regulatory Resources, Inc.

PHMSA, in coordination with NRC, published HM-250 in the Federal Register on July 11, 2014. Becoming effective on October 1st, this final rule seeks to amend the HMR in order to harmonize with recent changes from the IAEA concerning the transportation of Class 7 materials.



The Journal of HazMat Transportation’s Exclusive Comments on the U.S. DOT Letters of the Hazardous Materials Regulations                       25-29

By Frits Wybenga, Senior Technical Advisor

  • Use of ICAO; US Variations to ICAO; Approvals for large lithium batteries
  • Transloading and the role of the carrier
  • Conversion of liquid volume to mass in the case of air accessibility requirements


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: May and June 2014. Twenty-eight letters sorted, indexed and provided verbatim. 


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