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Recent Issue Summaries

In This Issue: March/April 2016 Issue

Topics of interest in the March/April 2016 issue of The Journal of HazMat Transportation.

COMPARING OSHA AND DOT HAZCOM REQUIREMENTS FOR BULK TRANSPORT CONTAINERS
The issue of how and what must be displayed on large volume hazmat containers in transportation is receiving attention with the implementation of the GHS under OSHA’s Hazard Communication Standard, 29 CFR 1910.1200 (HCS) and recent OSHA interpretive documents. This review takes a critical look at DOT requirements/interpretations and new OSHA HCS requirements and interpretations.
OSHA and DOT HazCom Requirements for Bulk Containers

SELECTIVE TESTING OF NON-BULK PACKAGING --INTERPRETATIONS
The Hazardous Materials Regulations (HMR) provide relief from rigorous design qualification testing requirements of Part 178, Subpart M, for non-bulk packagings which differ only in minor aspects from packagings which have undergone design qualification testing. This article looks at selective testing provisions for non-bulk combination packagings and related guidance provided in letters of interpretation issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA).
A Look At Selective Testing Provisions for Non-Bulk Packagings and Related Interpretations—Part A: Combination Packagings

TRANSPORT CANADA SEEKS CLOSER HARMONY WITH U.S. AND INTERNATIONAL STANDARDS
Transport Canada has opened consultation with stakeholders on how to best update and harmonize Canadian Transport of Dangerous Goods regulations with international standards such as the United Nations Model Regulations on the Transport of Dangerous Goods (UN Recommendations) and the U.S. Hazardous Materials Regulations. This article examines the goals and proposed changes of this harmonization initiative.
Transport Canada Move to Increase Harmony with International Regulations

OSHA GUIDANCE FOR HAZCOM 2012
OSHA recently published guidance, titled Hazard Classification Guidance for Manufacturers, Importers, and Employers, to provide assistance for those classifying chemical substances and mixtures under OSHA’s revised Hazard Communication Standard (29 CFR 1910.1200). This article reviews the guidance document and provides information on OSHA’s request for comments on a draft companion document, Guidance on Data Evaluation for Weight of Evidence Determination.
OSHA Publishes Guidance for HazCom 2012

HAZMAT REGULATORY REVIEW FOR 2015/ PREVIEW OF 2016 REGULATORY AGENDA
This review highlights the hazardous materials-related rulemaking activities of PHMSA and other DOT modal administrations for 2015 and looks at anticipated rulemaking activities for 2016.
HAZARDOUS MATERIALS TRANSPORTATION — Part A: Regulatory Highlights For 2015
Part B: Preview of the 2016 Regulatory

STATE REGULATORY ACTION: RAIL FEE COLLECTION AND EQUIPMENT SHARING
Under recently enacted legislation, the State of California’s newly created Regional Railroad Accident Preparedness and Immediate Response Fund Advisory Committee is charged with assessing fees to chemical companies shipping the top 25 hazardous materials transported by rail. The money collected will be used by the State of California to help pay for equipment, training, and resources for emergency preparedness and response. The railroads are not being assessed fees but are held accountable for collecting the fees from the shippers. This article describes recent activities arising from the legislation.
State Regulatory Action

THE JOURNAL ANSWERS READERS’ QUESTIONS
This article responds to recent questions from readers on four topics: use of a UN-certified packaging for limited quantities, reuse of US-manufactured UN drums for export to the US, provision of emergency response information under the ICAO Technical Instructions, and how use of an overpack should be reflected on a transport document for air shipments.
Readers’ Inquiries

COMMENTS ON DOT LETTERS OF INTERPRETATION
Comments are provided on recent interpretations from DOT concerning the proper shipping description for diesel fuel shipped as a combustible liquid, package testing requirements for biological substances, use of a secondary means of closure, and external inspections for rail tank cars.

Comments on DOT Interpretations

QUALIFICATION OF INDUSTRIAL PACKAGINGS UNDER ISO 1496-1
This article explores the complexities of, and provides guidance for, qualifying a freight container for use as a Type IP-2 or IP-3 industrial packaging under § 172.411 of the HMR and the freight container certification provisions of the ISO 1496-1 standard.
Type IP-2 or IP-3 Qualification under the Alternate ISO 1496-1 Standard

NTSB RECOMMENDATIONS ON LITHIUM BATTERY SEGREGATION IN SHIPMENTS
The NTSB recently issued two safety recommendations, A-16-001 and -002, to PHMSA addressing the transportation of lithium batteries as cargo on aircraft, concerning segregation from flammables and establishment of requirements for maximum loading densities. This HazMat Alert reviews the recommendations.
NTSB Issues New Safety Recommendations for Lithium Batteries Transported as Cargo on Aircraft