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Current Issue

The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 29, Number 3 September/October 2018


In This Issue           

From the President’s Desk   

PHMSA Penalties: July and August 2018

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

Rule and Rulemaking Summary



A Summary Review of Recent and Important DOT Letters of Interpretation of the Hazardous Materials Regulations from July and August 2018.
By Ed Mazzullo, Senior Technical Advisor

  • Emergency Response Telephone Number Exception for Engines17
  • Shipping Descriptions: Modifying Text in Italics xx
  • Applicability of CDL Hazmat Endorsement to Transport of Class 9xx
  • Attendance Requirements for Fuel Oil Deliveriesxx
  • Applicability Of Hazmat Training to a Lab Employeexx
  • Use of IMDG Code Class 7 Enlarged Labels in Place of Placardsxx
  • Testing a Partially Assembled Lithium Ion Batteryxx



What is Transportation Risk Management and Why Should We Consider It?
Part I of a Series
By Cherry Burke, Technical Advisor

In this first of a series article, the author looks at the meaning of transportation risk management and its importance to the hazardous materials industry. Future segments will include an overview of a comprehensive risk management program; risk prioritization; risk assessment; risk reduction; and risk management vs. risk elimination.



Rebuilding America’s Infrastructure – A Placeholder for HazMat Transportation Legislation
By Cynthia Hilton, Legislative Advisor

Since 1998, provisions to reauthorize the Hazardous Materials Transportation Act (HMTA) have been part of comprehensive bills to address “Surface Transportation” needs. The latest such legislation is the Fixing America’s Surface Transportation (FAST) Act, which reauthorized the HMTA through Fiscal Year (FY) 2020. This report looks at efforts to extendfunding for the HMTA by one FY until 2021 and the rationale for doing so.



Report on Proposals Discussed at the 53rd Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods
By Christopher Lind, Technical Advisor; Compiled by JHMT Staff 

From June 25 – July 4, 2018, the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (SCETDG) held its 53rd session in Geneva, Switzerland. The SCETDG addressed 60 formal proposals (working papers) in 9 general topic areas as well as 73 informal (INF). Additional INF papers were presented prior to or at the meeting. This is the third session of the new biennium. Changes to the UN Model Regulations agreed at all four sessions of this biennium will form the basis for amendments included in the 21st revised edition.

Report on the 35th Session of the UN Globally Harmonized System Sub-Committee Meeting
By Michele Sullivan, Technical Advisor

The GHS Sub-Committee (or UNSCEGHS) met in Geneva on July 4-6, 2018 for its 35th session and third session of the 2017-2018 biennium which will result in the 8th revision to the GHS. This report reviews and summarizes the discussions and papers from the 35th session. 

Global Developments in the Globally Harmonized System of Classification
By Michele Sullivan, Technical Advisor 

The UN Globally Harmonized System (GHS) of Classification and Labelling of Chemicals is frequently in the news these days. In this report, Dr. Sullivan provides information on some recent global GHS developments.



By Frits Wybenga, Senior Technical Advisor 

  • Use of Mismarked UN Packages Manufactured Overseas for which a European Competent Authority Approval Has Been Issued
  • Packaging for Div. 4.2 Materials Which Are “Wetted Solids”



Barriers for Permeation Control in Plastic Packaging
By Christopher Lind, Technical Advisor

This article reviews the importance of permeation control in plastic packagings and the pros and cons of several types of commonly used barriers.



Radioactive Material Type A Package – The User’s Recordkeeping Requirement
By Wade Winters, Technical Advisor

In this article, the author addresses changes to recordkeeping requirements for Type A packages made in the 2014 HM-250 rulemaking, which added more detailed language describing the kinds of information expected. Clarifications are offered on provisions that seem to be causing confusion to some.



Changes to the Class 8 Corrosive Classification Criteria
By Frits Wybenga, Senior Technical Advisor

Amendments to the classification criteria for Class 8 were incorporated in Chapter 2.8 of the twentieth edition of the UN Model Regulations. As the initial implementation of these changes on 1 January 2019 approaches, this report takes a look at how they may impact classification.



New Federal Enforcement Perspectives
By Richard Bornhorst, Technical Advisor

In this article, the author looks at the challenges facing government agencies with hazardous materials transportation enforcement responsibilities and what government agencies are doing to meet them.



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

  • Periodic retesting of combination packagings when held in inventory
  • Identification of the type of packagings


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: July and August 2018. 28 letters sorted, indexed and provided verbatim.

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