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Recent Issue Summaries

In This Issue: March/April 2017

Topics of interest in the March/April 2017 issue of The Journal of HazMat Transportation.

IMPACTS OF DELAY OF THE HM-215N INTERNATIONAL HARMONIZATION RULE
The HM-215N International Harmonization final rule was on display at the Federal Register to be published the next day, when the White House issued a “regulatory freeze” which necessitated withdrawal of the rule. This report looks first at potential impacts if the regulatory changes embodied in the rule are significantly delayed for with regard to many of the changes embodied in the rule. A second part focuses on provisions addressed to lithium batteries.
The Ramifications of Not Issuing HM-215N, The International Harmonization Final Rule
The Impact on Lithium Battery Transport by PHMSA Not Issuing HM-215N, The International Harmonization Final Rule

CANADIAN GHS IMPLEMENTATION
Health Canada’s Workplace Hazardous Materials Information System (WHMIS 2015) now incorporates the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) for workplace chemicals. This article reports on the status of implementation of the GHS in Canada, including guidance on compliance dates, classification, labeling, safety data sheets, and where to get additional information.
Canada Implements the GHS: Are You Ready for WHMIS 2015?

HAZMAT REGULATORY REVIEW FOR 2016/ PREVIEW OF 2017 AGENDA
This two-part review highlights the hazardous materials-related rulemaking activities of PHMSA and other DOT modal administrations for 2016 (Part A) and looks at anticipated rulemaking activities for 2017 (Part B). Hazardous Materials Transportation Regulations
Part A: Regulatory Highlights for 2016
Part B: Preview of Regulatory Activity for 2017

CHANGING REGULATORY PRIORITIES AND PROCEDURES
The new administration recently has issued executive orders and other directives and guidance aimed at reducing regulations, controlling regulatory costs, identifying and reducing regulatory burdens, among others. A sixty-day freeze on issuing new regulations was put into effect on January 20, 2017. A policy has been implemented requiring the elimination of two existing regulations for each new regulation that imposes costs. This article provides a review of the new policies and their potential impacts.
Administering the Administrative State: Regulatory Reform in the Trump Era

OFFERING AN “EMPTY” RADIOACTIVE MATERIAL PACKAGING FOR SHIPMENT
This article covers packaging exceptions under the HMR that may apply to shipment of an empty packaging that previously contained a radioactive material and other provisions addressed to radioactive materials that may not be applicable. The person asking was concerned because some in the regulated community were looking to impose the same requirements on the user as if the packaging held content.
Radioactive Material Empty Packaging – A Good Exception

POSTAL SERVICE TIGHTENS MAILING STANDARDS FOR LITHIUM BATTERIES
The Postal Service has proposed to revise Publication 52, Hazardous, Restricted, and Perishable Mail, to provide new mailing standards for lithium batteries. The intent is to align its standards with PHMSA’s changes to provisions for lithium batteries in the Hazardous Materials Regulations, as proposed in the HM-215N International Harmonization rulemaking, and recent changes to lithium battery provisions in the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air. This article reviews the changes to the mailing standard.
US Postal Service Proposes to Revise Mailing Standards for the Transport of Lithium Batteries

RSAC REGULATORY DEVELOPMENT ACTIVITIES
The Railroad Safety Advisory Council (RSAC) is a formally chartered and structured Federal Advisory Committee and provides a forum for collaborative rulemaking and program. In this article, the author highlights the regulatory development initiatives currently being worked on by RSAC’s Hazardous Materials Working Group and reports on arrangements for the next full meeting of RSAC.
March 2017 Railroad Safety Advisory Council Update

COMMENTS ON DOT LETTERS OF INTERPRETATION
Comments are provided on recent interpretations from DOT concerning:

  • Relief Valve Settings for Mc331 Cargo Tanks
  • Definition of a Flexible Intermediate Bulk Container

FOCUS ON TWO DOT LETTERS OF INTERPRETATION

  • A Review of Package Marking Requirements for ID 8000 Consumer Commodity Shipments
  • A Discussion on the Number of Package Samples Used for the UN Performance Tests

Summary of U.S. DOT Rule & Rulemaking Activity