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The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 28, Number 3 September/October 2017

In This Issue 1


PHMSA Penalties:  July and August                      67-CIII


Compliance Dates:  Also go to for this file, containing links to official documents and our reports. 50-52 Users Guide: A resourceful tool for navigating the contents of the Journal’s website.



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 July and August 2017.

  • Specification Plate Test Pressure Marking on a DOT 400-Series Cargo Tank  
  • Applicability of the Lithium Battery Mark for Smaller Lithium Batteries Contained in Equipment         
  • RQ Designation ON Shipping Papers to or from Canada               
  • Classification of an Internal Combustion Engine with Installed Class 1 Components       
  • Five Year Service Life Limitation for Plastics Drums and Jerricans
  • Filling A Specification Portable Tank with a Non-Regulated Materials

By Ed Mazzullo, Technical Advisor



PHMSA Clarifies New Status Designations for oCFR Letters of Interpretation          
By Ed Mazzullo, Technical Advisor, and JHMT Staff 

Interpretations in PHMSA’s online Code of Federal Regulations (oCFR) are grouped into three distinct status categories: “Current,” “Use Caution,” and “Historic.” We recently requested clarification from PHMSA as to the meaning of these terms. In this report we present our questions, PHMSA’s responses, and Mr. Mazzullo provides some technical commentary.



A Tutorial on Flammable Liquids and Their Classification     
By Frits Wybenga, Senior Technical Advisor

This report looks at PHMSA’s statistical data surrounding Class 3 flammable liquids and combustible liquids. Mr. Wybenga uses that data to support an investigation and explanation into the behavior of flammable liquids as well as the consequences of spills and ignitions.



Identification Numbers on a Transport Unit for a Class 9 Material Excepted from Placarding             
By Ed Mazzullo, Technical Advisor

This report provides a vital update to Ed Mazzullo’s report in the May/June 2017 issue regarding ID numbers in the situation of a shipper offering IBCs containing Class 9 material for domestic transportation. Further history of the regulatory history is explored and the requirements for ID number markings are clarified.



USPS Revises Mailing Standards for Lithium Batteries              
By Ed Mazzullo, Technical Advisor  

On August 17, 2017, the Postal Service published changes to Publication 52, Hazardous, Restricted, and Perishable Mail, to alignprovisions for lithium batteries with provisions in the ICAO TI and with changes to the HMR in the HM-215N final rule published on March 30, 2017. Read to know what changes will appear in the next update to Publication 52 and were effective upon publication in the Postal Bulletin, August 17, 2017.



Report on 33rd Session of the UN GHS Sub-Committee Meeting         
By Michele L. Sullivan, PhD, Technical Advisor

Dr. Sullivan provides this in-depth report summarizing the discussions and papers from 33rd session of the United Nations Sub-Committee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals (UNSCOE GHS) which met in Geneva on July 10-12, 2017. Issues covered include: Dust explosion hazards; use of non-animal testing methods for classification of health hazards; practical classification issues; chemicals under pressure; labeling of small packagings; among many others.

7th Revision of GHS Is Published              
By Michele R. Sullivan, PhD    Technical Advisor

Read for a summary and discussion of major changes in GHS Revision 7. Revisions cover: criteria for classification of flammable gases; health hazard definitions; precautionary statements and pictograms; SDS Section 14; and a new example for fold-out labels on small containers has been added.



Consolidation of Registration for Businesses with Separate Business Units     
By Ed Mazzullo, Technical Advisor

In this report, guidance is provided regarding registration requirements for large businesses with multiple business units, in particular the suitability of consolidating into a single US DOT number.



Resources and Funding of PHMSA’s Hazardous Materials Program
By Cynthia Hilton, Legislative Advisor 

From budget request to Congress appropriations, this report follows the funding process for the Pipeline and Hazardous Materials Safety Administration’s Office of Hazardous Materials Safety (PHMSA OHMS). Ms. Hilton helpfully provides both the regular order for the process as well as what can more realistically be expected based on recent years. Further detail is examined, such as the value added by OHMS, as well as the Congressional response to pending funding bills.



Questions & Answers on An Array of HazMat Issues    
By Wade Winters, President, Regulatory Resources, Inc.

A wide range of questions are addressed in this report, from inquiries to class 7 defining criteria and surface contaminated objects, to single packaging in combination configuration, UN packaging for explosives and use of single tested packagings, TSDF reshipping of RCRA hazardous waste, UF6 and LSA material, and completing the EPA manifest or referencing an attached shipping paper.



Transitional Provisions for HM-218H Requirements for Nitric Acid Packaging and Emergency Phone Numbers    
By Ed Mazzullo, Technical Advisor           

PHMSA issued Final Rule HM-218H Hazardous Materials: Miscellaneous Amendments on June 2, 2016, incorporating a number of changes to the HMR in response to petitions for rulemaking. Several organizations had requested one-year transition periods. In response, PHMSA had stated they would “[issue] a Federal Register publication to respond to your appeal and to extend the compliance date for the modified nitric acid packaging requirement by one year until July 5, 2017.” This report explores the regulatory effect in the interim as the July 5, 2017 date has passed without changes to the final rule.


Changes to the 59th Edition of the IATA Dangerous Goods Regulations        
By JHMT Staff

The 59th edition of the International Air Transport Association Dangerous Goods Regulations (IATA DGR) incorporates all amendments made by the IATA Dangerous Goods Board and includes addenda issued to the 2017–2018 edition of the International Civil Aviation Organization's Technical Instructions (ICAO TI). Changes in the 59th DGR become effective January 1, 2018.



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

  • §175.26 applicability of air cargo notification requirement
  • Applicability of Security Plan Requirements to Unloading a CTMV
  • 171 Subpart C: 171 Subpart C: Application of requirements to a freight forwarder acting under contract for the carrier to accept hazmat


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: X through X 2017. XX letters sorted, indexed and provided verbatim.     

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