Saturday, September 23, 2017
Text Size

Current Issue

The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 28, Number 2 July/August 2017

In This Issue 

PHMSA Penalties:  May and June  

Compliance Dates:  go to for this file, containing links to official documents and our reports. 42-44

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



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 through July 2017.

  • Horizontal Display of Words and ID Numbers on Placards 
  • Limited Quantity Provisions for "UN1324, Films, Nitrocellulose Base"    
  • Shipping Name and Identification Markings on a Non-Bulk Package        
  • USA Mark on a Packaging Manufactured in a Foreign Country                
  • Placarding and ID Number Markings on a Multi-Compartmented Cargo Tank       
  • Measuring Wall Thickness of DOT 2P and 2Q Containers           

By Ed Mazzullo, Technical Advisor



Who Is The Offeror For Transport By Vessel? The Performance of HazMat Pre-Transportation and Transportation Functions  
By Ed Mazzullo, Technical Advisor 

In this report, we have a complicated situation where one company believes the other should be named as the “Shipper/consignor” on the dangerous goods transport document, but the other claims that the first is the shipper and should be named as such on the transport document. Mr. Mazzullo attempts to unravel the situation within the constraints of the HMR and contractual obligations.



Acceptability of Using for Air Transport a Proper Shipping Name Marked on a Package According to the IMDG Code            
By Frits Wybenga, Senior Technical Advisor 

Will a proper shipping name marked on a package in accordance with the IMDG Code but which differs in some respects with the marking required by the ICAO Technical Instructions (or IATA DGR) be accepted when the IMDG Code marking is present in the case of air transport? Mr. Wybenga takes a full look at the question and international requirements.



Transport Canada’s Regulations Amending the Transportation of Dangerous Goods Regulations (International Harmonization Update, 2016)       
By Ed Mazzullo, Technical Advisor  

On July 12, 2017, Transport Canada’s Regulations Amending the Transportation of Dangerous Goods Regulations (International Harmonization Update, 2016), SOR/2017-137, was published in Part II of the Canada Gazette. Read this report for a thorough summary of changes adopted, regarding: U.S.-Canada Reciprocity; Incorporations by Reference—Dynamic Referencing; Definitions; Classification Criteria; Lithium Battery Handling Mark; among others.



Back to the Future – Truck Tracking           
By Cynthia Hilton, Legislative Advisor

Proposals for real-time tracking of motor carrier shipments date back to the late 80s. Though the regulated community has so far successfully argued their case against the feasibility and practicality of such tracking, recent DOT initiatives as well as TSA pilots have raised awareness of the contentious issue. Summarized are the recent actions of Interested Parties as well as legislative action.



Report on 51st Session of the UN Sub-Committee Meeting   
By Frits Wybenga, Senior Technical Advisor

The 51st session the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (UNSCETDG) was held in Geneva, Switzerland from July 3 – 7, 2017 for its first 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 of the UNMR. This full report discusses the outcome of formally submitted proposals and informal papers are discussed.



Report on ICAO Working Group 17  
By Frits Wybenga, Senior Technical Advisor

Mr. Wybenga reports on the second Working Group meeting of the International Civil Aviation Organization (ICAO WG). The WG primarily prepared amendments to the ICAO Technical Instructions (TI) to be submitted for consideration by the Dangerous Goods Panel in its fall 2017 meeting. Read to know the issues that were discussed and the outcome of discussions.

Speaking for You:  U.S. HazMat Representation at ICAO   
By Cynthia Hilton, Legislative Advisor

This report looks at the historic role of agencies serving as the U.S. competent authority to various international organizations including the Dangerous Goods Panel of the International Civil Aviation Organization, starting with PHMSA’s predecessor agencies, to PHMSA, and most recently, FAA. A movement remains seeking to restore PHMSA as designated lead, and Ms. Hilton looks at the most recent attempts on part of both legislators and interested parties.



A Reader Noting Problems in Transporting Jet Engines in Asia Inquired into the Transport of Jet Engine Ignition Exciters Containing a Small Quantity of Radioactive Material    
By Frits Wybenga, Senior Technical Advisor

A question arises that essentially asks at what point do ignition exciters stop being regulated for the purposes of transport while installed in machinery? What follows is a careful examination of the US CFR and DOT letters of interpretation to be held in contrast to the ICAO TI. Read for a thorough review of the regulatory possibilities.



Updates to PHMSA’S Regulatory Agenda  
By Ed Mazzullo, Technical Advisor

The Unified Agenda of Regulatory and Deregulatory Actions, usually updated each spring and fall, provides an updated report on the actions Federal agencies plan to issue in the near and long term. Following his review of PHMSA’s rulemaking schedule in the March/April issue, Mr. Mazzullo summarizes the PHMSA regulatory actions which appear in the “Update 2017” edition of the Unified Agenda.

Update and Summary on ANPRM HM-251D Hazardous Materials: Volatility of Unrefined Petroleum Products and Class 3 Materials       
By Ed Mazzullo, Technical Advisor

HM-251D advance notice of proposed rulemaking (ANPRM), Docket No. PHMSA-2016-0077, was originally issued on January 18, 2017. In the meantime, debate on the proposed regulatory changes has been nonstop, with concerned individuals and organizations submitting their comments to PHMSA both in support of and against the ANPRM. Mr. Mazzullo summarizes the feedback from the public comments submitted ahead of further DOT action.



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

  • Proper shipping name for a flammable liquid reclassed as a combustible liquid
  • Packagings Qualifying for the “USA” Mark
  • Transport of Zone B TIH in a Freight Container


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: March through July 2017. 31 letters sorted, indexed and provided verbatim.      

Copyright 2017, PRI International, Inc. All Rights Reserved.

The Journal of HazMat Transportation and its Digital Edition is published bi-monthly and HazMat Alerts are issued severally per month by PRI International, Inc. Subscription licensing inquiries and letters to The Journal of HazMat Transportation should be directed to PRI International, Inc., P.O. Box 3144, West Chester, PA 19381-3144, tel. (610) 436-8292, or fax (610) 436-9422. E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

IMPORTANT NOTICE: Reproduction in part or whole, or the derivation of content for external or internal redistribution via print, facsimile, electronic, or any other means, of content presented in The Journal of HazMat Transportation (print and digital) editions, HazMat Compliance Alerts, The HazMat Reference Gateway™, and The HazMat Compliance DataBase™  is prohibited without explicit prior written permission from the publisher (see Title 17 USC),  or unless commercial arrangements have been made via subscription license, available to all subscribers. Violators may be subject to fees by PRI International, Inc.  PRI International, Inc. will enforce its intellectual property rights to the fullest extent provided by United States and International law against all violators.

Single user content licensing and multiple user agreements are available which provide for rights to the internal distribution of content. Call (610) 436-8292 for information.  Complete intellectual property provisions and guidelines for use are found at

PRI International, Inc. hereby disclaims responsibility for any statements made or opinions expressed in its publications by individual or group contributors.