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Recent Issue Summaries

In This Issue: September/October 2015 Issue

A sampling of topics of interest in the September/October 2015 issue of The Journal of HazMat Transportation.

EUROPEAN ACCEPTANCE OF USA-MARKED PLASTIC PACKAGES
A question has arisen as to whether filled plastic packagings with a “USA” UN mark will be accepted for transport to final destination throughout Europe. It has been suggested that USA-marked packagings were only accepted up to the first warehouse delivery point after sea or air transport from the US. This article answers the question. Acceptance of Filled “USA” Marked UN Plastic Packagings in Europe, page 16-17

POST-HM-251 RAIL SAFETY ACTIVITIES BY THE NTSB AND STATES
Part 2 of a report on the impacts of the HM-251 final rule (Part 1 appeared in the August/September edition of The Journal), this article reviews recent rail-safety related activities, including a National Transportation Safety Board (NTSB) brake study, new Transport Canada and Federal Railroad Administration rules for unattended trains, and actions being taken by various state governments addressing the risks of crude oil and similar materials by rail. The HM-251 Final Rule’s Impact Part 2: NTSB Brake Study and Recommendations by State Governments, page 18-21

CHANGES TO EXCLUSIVE USE AND RADIOLOGICAL SURVEY REQUIREMENTS
This article reviews the impacts of recent regulatory changes affecting exclusive use shipments of radioactive materials and radiological survey requirements. Exclusive Use and Radiological Survey Requirements – The New Requirements, page 40-41

CORROSIVITY CLASSIFICATION ISSUES UNDER THE GHS
Use of the Globally Harmonized System’s (GHS’s) provisions for classification and packing group determinations for corrosive materials may lead to higher transportation costs. This article provides an overview of the GHS tiered classification process and addresses current issues. The Journal solicits input from our readers on the problems they may be facing in classifying corrosive products for export to Europe and elsewhere. Transport Corrosivity Issues Brought on by GHS, page 7-9

DOT INTERPRETATIONS ON EMERGENCY RESPONSE INFORMATION
This article provides an overview of the current regulatory requirements for emergency response information and summarizes a number of the many letters of interpretation that the Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued in recent years in response to inquiries concerning these requirements. LOOKING AT EMERGENCY RESPONSE INFORMATION AS ADDRESSED IN DOT LETTERS OF INTERPRETATION, page 27-29

PRE-MEETING REPORT FOR THE 25TH SESSION OF THE ICAO DANGEROUS GOODS PANEL
The twenty-fifth session of the ICAO Dangerous Goods Panel will meet from October 19-30, 2015, in Montréal, Canada. The meeting will lead to amendments to the ICAO Technical Instructions for the 2017-2018 edition which will be effective beginning January 1, 2017. This article summarizes, and provides links to, the 47 working papers to be considered at the meeting. The 25th Session of the ICAO Dangerous Goods Panel Pre-Meeting Report: Review of Papers, page 30-33

COMMENTS ON RADIOACTIVE MATERIALS INTERPRETATIONS
This article analyzes two recent interpretations issued by PHMSA, one concerning the shipping description for a Class 7 (radioactive) YELLOW III- labeled package in a rigid overpack and the other on how to describe an externally contaminated non-spillable wet acid battery that meets Class 7 defining criteria. Two Reviews of DOT Letters of Interpretations, page 34-39

HM-233E FINAL RULE--SPECIAL PERMIT AND APPROVALS ADMINISTRATIVE PROCEDURES
This article (HazMat Alert 2015-43) reviews PHMSA’s latest final rule, HM-233E. The final rule, responds to a Congressional mandate and adopts regulations setting forth standard operating procedures (SOPs) to support the administration of PHMSA’s special permit and approval programs, and objective criteria to support the evaluation of special permit and approval applications, such as for determining the fitness of applicants to conduct operations requested in a special permit or approval application. PHMSA Issues HM-233E Final Rule: Special Permit and Approvals Operating Procedures and Evaluation Process, page 27-29

COMMENTS ON DOT LETTERS OF INTERPRETATIONS
Comments are provided on recent interpretations from DOT concerning whether a carrier assumes the role of shipper when using a salvage package, describing an oxygen cylinder with attachments as a “Lifesaving appliance”, and size limits for DOT 39 cylinders used for liquefied flammable gases. Comments on DOT Interpretations, page 22-26