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The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 28, Number 1 May/June 2017

27th Anniversary Issue

In This Issue 


PHMSA Penalties:  March and April                 

Compliance Dates:  go to for this file, containing links to official documents and our reports. 46-48



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 March and April 2017.

  • Permanent Installation of Delivery Hose Assemblies on MC331 Cargo Tanks
  • Overpack for Shrink-Wrapped Aerosols Glued to Trays
  • Number of Button Cells Contained in Equipment
  • Hazmat Training for Manufacture and Inspection of Nurse Tanks 
  • Segregation Distance for Lab Packs Containing Incompatible Materials
  • Determining the RQ for a Hazardous Substance Based on Particle Size
  • Marking of Aerosol Containers 
  • Inspection of Threads on Dot 3A, 3AX, and 3E Seamless Steel Cylinders

By Ed Mazzullo, Technical Advisor



How HM-215N Differs from the UN Requirements for Polymerizing Substances  
By Frits Wybenga, Senior Technical Advisor

Under recently issued Final Rule HM-215N, the polymerizing substance hazard is being defined and included as one of the hazards of Division 4.1. Some disharmony with international standards has been introduced. Mr. Wybenga goes in-depth on definitions, criteria, package selection, and the differences in shipping under international regulations and domestic transport.



Differences Between the International Transport Rules and the Provisions in the U.S. 49 CFR Regulations for Lithium Batteries 
By Frits Wybenga, Senior Technical Advisor

Although the publication of Final Rule HM-215N updated many US HMR regulations to harmonize with international standards, some international requirements were not included in HM-215N. In particular, PHMSA did not adopt requirements on “Enhanced Safety Provisions for Lithium Batteries Transported by Aircraft” and stated its intent of adopting these additional provisions through a separate rulemaking. Mr. Wybenga examines this issue, from the development of the enhanced requirements to packing instruction changes.



Canada’s “Proof of Classification” Requirement  
By Frits Wybenga, Senior Technical Advisor

This report continues the discussion from Barbara Foster’s report in the Nov/Dec 2015 issue of The Journal on Transport Canada’s apparent deviation from consistency with the UN Model Regulations and the HMR with the new “proof of classification” requirement. Mr. Wybenga looks at applicability, the definition of proof of classification, and  provides guidance for those asked for proof of classification.

By Ed Mazzullo, Technical Advisor 

Mr. Mazzullo provides a review of Canada’s initiatives with respect to Standard TP 14850 Small Containers for Transportation of Dangerous Goods, Containers for Transport of Dangerous Goods by Rail, as well as its updates to its Marine Provisions, Emergency Response Assistance Plan, and harmonization of the TDG with UN Model Regulations, the IMDG Code and the ICAO Technical Instructions



Packaging Provisions for Organic Peroxides: Why No Packing Groups 
By Ed Mazzullo, Technical Advisor

Mr. Mazzullo responds to questions raised by a reader, explaining PHMSA’s decision to drop packing groups for all Organic Peroxide entries from the HMR and what the underlying rationale was.

Inner Packaging "Surrounded" with Absorbent 
By Frits Wybenga, Senior Technical Advisor

In this report, Mr. Wybenga responds to a reader question and examines what PHMSA intended with the word "surrounded" in 173.12(b)(2)(i) and requirements for chemically compatible absorbent material



Pre-Meeting Report on Proposals to be Discussed at the 51st Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods 
Compiled by JHMT Staff and Reviewed with Comments by Frits Wybenga, Senior Technical Advisor

From July 3 – 7, 2017, the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (SCETDG) will hold its 51st session in Geneva, Switzerland. The SCETDG agenda will address 28 formal proposals (working papers) in seven general topic areas as well as 1 informal (INF) paper as of the time of publication. This report gathers and summarizes all working proposals to the meeting, as well as all informal papers available at the time of writing.



Review of Papers of the ICAO Dangerous Goods Panel Working Group 2017 (DGP-WG/17)     
Compiled by JHMT Staff and Reviewed with Comments by Frits Wybenga, Senior Technical Advisor

The 2017 meeting of the Dangerous Goods Panel Working Group (DGP WG) of the International Civil Aviation Organization (ICAO) met from April 24-28, 2017, in Montréal, Canada.  A major focus was incorporating amendments incorporated into the UN Model Regulation in the 20th revised edition, as well as continuing to discuss issues raised by DGP members. This report summarizes the working papers on the agenda.



PHMSA Interpretation of Information Requirements for Type A Package Documentation 
By Wade Winters, President, Regulatory Resources, Inc.

Mr. Winters provides this look at a letter of interpretation concerning shippers of radioactive material utilizing Type A packagings. The letter concerned the enhanced Type A package recordkeeping requirements, and Mr. Winters reviews PHMSA’s response in detail.



Leading Change:  Opportunities for Regulatory Reform 
By Cynthia Hilton, Legislative Advisor

This report covers a recent hearing held by the US House of Representatives’ Subcommittee on Railroads, Pipelines, and Hazardous Materials chairman. Witnesses represented companies and workers subject to regulations promulgated by PHMSA and FRA. A wide range of topics were discussed.



  • Identification Numbers on a Transport Unit for a Class 9 Material Excepted from Placarding    
  • Confusion Over Display of ID Numbers on Non-Bulk Packages
  • Additional Shipping Paper Description Requirements for a Marine Pollutant
  • lacarding and ID Numbers for a Transport Unit Containing a Mixed Load

Answered by Ed Mazzullo, Technical Advisor

Mr. Mazzullo lends his expertise to demystifying some practical concerns regarding the applicability of certain hazard communication provisions of the Hazardous Materials Regulations. Questions are paraphrased.


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

  • New Type of Lithium Battery
  • Applicability of Marine Pollutant Requirements to Aerosols
  • Offeror at Oil Production Locations


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: March and April 2017. 29 letters sorted, indexed and provided verbatim. 

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