Monday, September 24, 2018
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2018-09 May 2, 2018 Part Two: Comments on the HM-219A Petitions for Rulemaking NPRM: Other Issues

By Ed Mazzullo, Technical AdvisorMay 2, 2018


Yesterday, The Journal issued its report, A Look at Comments to the HM-219A Petitions for Rulemaking NPRM: Part One: Packaging Issues by Ed Mazzullo, Technical Advisor in anticipation of a final rule to be issued by PHMSA in the near future. On June 30, 2016 PHMSA issued the HM-219A 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 Part 2 report, Ed Mazzullo conducts a review of comments on a range of issues not covered in his previous Part 1 report.

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 when issued.

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

  • Incorporations by Reference (“IBR”; § 171.7 and other sections)
  • Definitions for “Basic Description” and “Shipping Description” (§171.8)
  • Electronic Signatures for the Hazardous Waste Manifest (§ 172.205)
  • Inconsistencies between Domestic and International Labels and Placards; Printing Tolerances for Labels and Placards (§§ 172.407 and 172.517)
  • Emergency Response Numbers (§ 172.604)
  • Shipping Names for Materials on Roadway Striping Vehicles (§173.5a)
  • Units of Measurement for Limited Quantities of Ethyl Alcohol (§ 173.150)
  • Limited Quantities of Ammonium Nitrate by Vessel (§ 176.415)
  • Service Pressure Marking for DOT 8 and DOT 8L Cylinders (§ 178.35)
  • Recordkeeping Requirements for Portable Tanks (§ 180.605)

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