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The Journal of HazMat Transportation

A Publication of PRI International, Inc.

Volume 26, Number 2 July/August 2015

In This Issue


Summary of U.S. D.O.T. Rule & Rulemaking Activity     66-67

Also go to, Critical Dates. Summaries are linked to our reports and Federal Register notices.

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

PHMSA Penalty Violations   68-CIII

U.S. DOT, PHMSA Closed Penalty Cases

 HazMat Alerts Issued Since Last Issue     34



A Summary Review of Recent and Important DOT Letters of Interpretation of the Hazardous Materials Regulations from May and June 2015.

  • Use of ERG Guide Number on a Shipping Paper     11
  • Outer Packaging for Lithium Batteries Contained in Equipment      14
  • Eligibility for Small Quantity Exceptions      18
  • ID Numbers on a Multi-Compartmented Cargo Tank           20
  • Time Frame for Cargo Tank Periodic Testing            21
  • Use of Cargo Aircraft Only Label on a Highway-Only Shipment    23
  • Shipment of Lithium Batteries as Household Hazardous Waste       28
  • Using Initials for the Shipper’s Certification 29
  • Use of Punctuation in Shipping Paper Descriptions              31
  • Shipping Name for Non-Spillable Batteries Installed in Devices      33
  • Cargo Tank Marking with Shipping Name as Part of Company Name         34

By Ed Mazzullo, Technical Advisor



Report of the 47th UN TDG Sub-Committee Meeting: June 2015, First of the New Biennium           13-16
By Frits Wybenga, Senior Technical Advisor

The Sub-Committee of Experts on the Transport of Dangerous Goods met from June 22nd to 26th for its 47th session. It was the first of four meetings for the biennium that will eventually lead to the 20th edition of the UN Model Regulations. The Model Regulations provide a look at the future as they lead to amendments to worldwide transport regulations. Read for a discussion of items of note, organized by agenda item.


OSHA Hazard Communication Requirements for Food and Wastes      27-29
By Michele Sullivan, PhD         

The Occupational Safety and Health Administrations Hazard Communication Standard (OSHA HCS) provides labeling exemptions for foods and hazardous wastes. Dr. Sullivan’s report discusses these exemptions, and relevant regulatory sections are provided at the end.


The New Requirements for Polymerizing Substances 30-33
By Frits Wybenga, Senior Technical Advisor

New requirements for polymerizing substances in the 19th edition of the UN Model Regulations are to become effective as of January 1, 2017. Mr. Wybenga provides an in-depth look at what are polymerizing substances, existing international requirements, the current HMR approach, and new requirements regarding special packaging provisions and classification.


Transport Canada Plans Update of Release Reporting Requirements   19-21
By Barbara Foster, ICC The Compliance Center

In part due to recent accidents, Transport Canada issued draft proposals to update the Canadian Transportation of Dangerous Goods Regulations for the first time since 2002. These amendments are intended to make it easier to gather data on dangerous goods accidents by amending reporting requirements of releases, losses, and undeclared or misdeclared shipments.


The HM-251 Final Rule’s Impact on Flammable Products          7-9
By Edward W. Pritchard, Senior Partner, Paladin Consulting Group

Final Rule HM-251, published in May, became effective as of July 7, 2015. The rulemaking provides two new definitions for trains transporting Class 3 flammable liquids. This report is the first in a series focusing on major concerns affecting industry.

Report on Appeals to Final Rule HM-251: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Train
By Edward Mazzullo, Technical Advisor

Issued on May 8, 2015, Final Rule HM-251, this highly controversial rule became effective as of July 7, 2015. PHMSA received a number of appeals requesting reconsideration of the provisions adopted therein. Six appeals were filed and may be addressed either through adjustments to the final rule or initiation of a notice of proposed rulemaking. Mr. Mazzullo presents a summary of the provisions of the final rule appears below, followed by a review of the individual appeals.


Report of the 23rd IMO Editorial and Technical Working Group – May 18-23, 2015   17-18
By Frits Wybenga, Senior Technical Advisor

The latest work at the meeting of the International Maritime Organization will lead to IMDG Code amendment 38-16, expected to become mandatory on January 1, 2018. This report of the IMO E&T Group provides a preview of editorial corrections and amendments to: viscous liquids; polymerizing substances; special provisions for vehicles and battery-powered vehicles; placarding of CTUs containing lithium batteries; among other subjects.


The Journal of HazMat Transportation’s Exclusive Comments on the U.S. DOT Letters of the Hazardous Materials Regulations                       22-26
By Frits Wybenga, Senior Technical Advisor

  • Training on Combustible Liquids for Air Transport (as Well as for Sea Transport under the IMDG Code) when the Training is ICAO (IATA) Based
  • Packaging Requirements for Export Shipments of Dangerous Goods
  • Use of a Secondary Means of Closure
  • Applicability of Materials of Trade (MOTs) Provisions


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: March, April, May, and June 2015. Fifty-one letters sorted, indexed and provided verbatim.        

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