Saturday, May 27, 2017
Text Size

Current Issue

The Journal of HazMat Transportation

A Publication of PRI International, Inc.


Volume 27, Number 6 March/April 2017

In This Issue 

PHMSA Penalties:  January and February  


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

Also go to, Critical Dates. Summaries are linked to our reports and Federal Register notices, and go back several years.

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



A Summary Review of Recent and Important DOT Letters of Interpretation of the Hazardous Materials Regulations from January and February 2017.

  • Continued Display of “PG II” on Pre-Printed Shipping Papers for Explosives
  • Exception from Pilot Notification Requirements for Certain Lithium Batteries
  • Shipping Papers: Placement of Number and Type of Package
  • Approvals for Reducing the Number of Samples Used in Testing Non-Bulk Packagings
  • Placarding a Pickup Truck-Trailer Combination
  • Transport of a Class 9 Hazardous Substance in Bulk
  • Marking Requirements for Highway Only Transport of “Id8000, Consumer Commodity, Class 9”
  • Shipping Paper Holder Mounted to the Driver’s Side Door

By Ed Mazzullo, Technical Advisor



A Review of Package Marking Requirements for ID 8000 Consumer Commodity Shipments
By Frits Wybenga, Senior Technical Advisor

In this report, Mr. Wybenga looks at the prior use, phasing out, and afterlife of the “consumer commodity” classification. Taking a recent DOT letter of interpretation as the basis, he goes through the use of preprinted packagings across different modes and the resulting requirements for marking.



Administering the Administrative State: Regulatory Reform in the Trump Era
By Ronce Almond, Marina O’Brien, and Andy Orr, The Wicks Group, PLLC

The new US President has been quick to implement a disruptive regulatory reform agenda. The legal experts of the Wicks Group, LLC, provide a detailed and readable analysis that examines the actions of the White House, the implications and questions raised, and gives a look at the big picture for federal regulators.



The Impact on Lithium Battery Transport by PHMSA Not Issuing HM-215N, The International Harmonization Final Rule
By Frits Wybenga, Senior Technical Advisor 

In this report, the other provisions of delayed Final Rule HM-215N are set aside to take an in-depth look at the complex issue of international harmonization with lithium battery provisions. He demonstrates how the US can adapt to what disharmony will be introduced as it falls behind international standards. In some cases, problems may be insignificant; for others, trouble could abound.

US Postal Service Proposes to Revise Mailing Standards for the Transport of Lithium Batteries  
By Ed Mazzullo, Technical Advisor

The US Postal Service is proposing to revise Publication 52 mailing standards for lithium batteries in order to align with both PHMSA’s proposed changes as well as recent changes in the ICAO Technical Instructions. Mr. Mazzullo’s report takes into account the circumstances surrounding PHMSA’s frozen HM-215N international harmonization Final Rule to provide a clear and detailed look at USPS’ proposed provisions.



A Discussion on the Number of Package Samples Used for the UN Performance Tests 
By Frits Wybenga, Senior Technical Advisor

Mr. Wybenga examines a recent DOT letter of interpretation addressing the reuse of packages in test procedures. This report takes a deep dive into the implementation of UN performance packaging requirements into the HMR and reviews how DOT’s stance has changed over the years.

Radioactive Material Empty Packaging – A Good Exception
By Wade Winters, President, Regulatory Resources, Inc.

If you have ever had a question regarding the use of a packaging that once contained radioactive material but had been emptied, this is the report to read. Mr. Winters examines HMR requirements against international regulations, the term “under conditions normally incident to transportation,” and how to avoid unnecessary over-compliance.



  • Executive Orders, Actions, and Related Memoranda
  • Guidance on Achieving US Harmonization with International Standards 

Prepared by JHMT Staff



March 2017 Railroad Safety Advisory Council Update
By Edward W. Pritchard, Senior Partner, Paladin Consulting Group

Mr. Pritchard continues his series providing updates on the tasks and recommendations of the Railroad Safety Advisory Council (RSAC). Information from the last meeting in September is presented as well as topics of current discussion. Read his report in preparation for RSAC’s next meeting in May.



The Ramifications of Not Issuing HM-215N, The International Harmonization Final Rule
By Frits Wybenga, Senior Technical Advisor

As those in the US await publication of Final Rule HM-215N, deadlines for compliance approach and those subject to regulation need to prepare for possible disharmony. Mr. Wybenga looks at those areas where he sees potential for solutions as well as pitfalls.

Hazardous Materials Transportation Regulations
Part A: Regulatory Highlights of 2016
Part B: Regulatory Preview of 2017
By Ed Mazzullo, Technical Advisor

In Part A of Mr. Mazzullo’s annual regulatory review, he looks at the rulemaking actions issued or otherwise active in 2016 and the first few weeks of 2017. Part B focuses on rulemaking activity scheduled or otherwise anticipated for the year. Taken together, they are essential reads for a well-rounded picture of the activeness of US hazmat regulation.



Canada Implements the GHS: Are You Ready for WHMIS 2015?   
By Michele Sullivan, Ph.D., Technical Advisor

Dr. Sullivan provides this in-depth report on the status of Canada’s adoption of elements of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) into the revised Workplace Hazardous Material Information System (WHMIS 2015), whose compliance date becomes effective June 1, 2017. Read for an understanding of the current situation in Canada as well as the interactions with the US hazcom system.



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

  • Relief Valve Settings for MC331 Cargo Tanks
  • Definition of a Flexible Intermediate Bulk Container


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: January and February 2017. 18 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.