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2018-08 May 1, 2018 Comments on the HM-219A Petitions for Rulemaking NPRM: Part One: Packaging Issues

By Ed Mazzullo, Technical AdvisorMay 1, 2018

On June 30, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued the HM-219A Notice of Proposed Rulemaking (NPRM), where it proposed to amend the Hazardous Materials Regulations (HMR) to update, clarify, or provide relief from miscellaneous regulatory requirements in response to 21 petitions for rulemaking submitted by the regulated community. In this report, Technical Advisor Ed Mazzullo conducts a review of comments that were submitted in response to the NPRM. Mr. Mazzullo looks at comments submitted in relation to packaging in this first of two reports. Part II, dealing with a range of other subjects, will be issued as a HazMat Alert on May 2, 2018. Our objective with the creation of these reports is to provide a basis for comparing comments submitted by respondents with the provisions of the final rule.

Areas covered in this report are as follows. Petitions are linked to their dockets in the online version of this report, login required.

  • Use of Combination Packagings Tested With Liquids for Solid Materials (§ 173.24a)
  • Lifespan for Toxic by Inhalation Tank Cars (§ 173.31)
  • Pallets for Limited Quantities (§ 173.156)
  • Cylinder Valves and Protection Caps (§ 173.301)
  • Testing for Aerosols (§ 173.306)
  • Basis Weight Tolerances for Fiberboard Used in the Manufacture of UN 4G Fiberboard Boxes (§ 178.516)
  • Marked Date of Manufacture on Composite IBCs (§ 178.703)
  • Test Pressures for Cargo Tanks (§ 180.407)

Click here to read Mr. Mazzullo's full report.


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Job Opening: Senior Logistics Safety Advisor

The Senior Logistics Safety Advisor is responsible for setting the necessary HSSE requirements across North America logistics activities for BP North America. As the Senior Logistics Safety Advisor, you will interface with businesses served by logistics to ensure Health, Safety, Security, and Environmental (HSSE) expectation are delivered. Additionally, you will provide logistics assurance services across all BP North American strategic performance units, business units, and rail operational sites.

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