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Recent Issue Summaries

In This Issue: September/October 2017

Topics of interest in the September/October 2017 issue of The Journal of HazMat Transportation.

“USE CAUTION” LETTERS OF INTERPRETATION
PHMSA’s online Code of Federal Regulations (oCFR) provides access to the HMR and links to approximately 5,800 letters of interpretation, many of which are assigned a status of “Use Caution.” In this article, PHMSA responds to questions posed by The Journal concerning this database. PHMSA CLARIFIES STATUS DESIGNATIONS FOR oCFR LETTERS OF INTERPRETATION

CLASSIFICATION OF FLAMMABLE LIQUIDS
In this first of two installments, The Journal conducts a basic review of the physical properties of flammable liquids and their behavior from a hazard perspective. The second installment will examine in some detail the classification of flammable/combustible liquids under the HMR and international regulations. A Tutorial on Flammable Liquids and Their Classification

OHMS BUDGET NOT FINALIZED
PHMSA’s Office of Hazardous Materials Safety (OHMS) is charged with ensuring the safe and secure transportation of hazardous materials in commerce, including aid to prepare emergency responders in the event of a hazardous materials incident. This mission includes rulemaking, issuing special permits and approvals, administering grants, engaging in international forums, compliance assistance, and enforcement, all of which require funds. This article examines the budgeting process in detail and the status of PHMSA’s budget request. Funding PHMSA

33RD SESSION OF THE UNSCEGHS
The United Nations Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UNSCEGHS) met in Geneva on July 10-12 for its 33rd session. This is the first session of the 2017-2018 biennium which will result in the 8th revision to the GHS. This report presents a summary of the discussions and papers from the 33rd session. Report on 33rd Session of the UN GHS Sub-Committee Meeting

REVISION OF THE UN GHS
The Globally Harmonized System of Classification and Labeling of Chemicals (GHS; also known as the “Purple Book”) is updated every two years. This article reviews the major changes in the recently issued 7th revised edition of the GHS, such as revisions to classification criteria for flammable gases, health hazards definitions, and precautionary statements and pictograms. 7th Revision of GHS Is Published

A TRAINER RESPONDS TO HAZMAT-RELATED QUESTIONS
A consultant and trainer presents a series of questions and responses on various hazmat-related subjects such as classification of surface contaminated objects, use of single packagings containing other packagings, UN packagings for explosives and others. Questions & Answers on An Array of HazMat Issues, page 35
READER INQUIRY: PROVIDING ID NUMBER MARKINGS FOR TRANSPORT VEHICLES CONTAINING A BULK PACKAGE
We revisit a reader inquiry concerning who is responsible for providing identification number markings, when the numbers are required to be displayed on a transport vehicle or freight container containing an IBC under § 172.331. The review suggests a need for clarification of the applicable regulations. Identification Numbers On A Transport Unit For A Class 9 Material Excepted From Plazarding

LITHIUM BATTERIES IN THE MAIL
On August 17, 2017 the Postal Service, in Postal Bulletin 22474, published changes to Publication 52, Hazardous, Restricted, and Perishable Mail, to provide new mailing standards for lithium batteries. This article reviews the changes to Publication 52 provisions for lithium batteries which are intended to align with the ICAO Technical Instructions and with changes to the HMR in the PHMSA HM-215N final rule. USPS Revises Mailing Standards for Lithium Batteries

COMMENTS ON DOT LETTERS OF INTERPRETATION
Comments are provided on recent interpretations from DOT concerning notification of hazardous materials requirements at air cargo facilities, applicability of security plan requirements to unloading a cargo tank motor vehicle, and how HMR and ICAO TI requirements apply in the case of a freight forwarder accepting hazmat for the carrier. Comments on DOT Interpretations

HM-218H TRANSITIONAL PROVISIONS
PHMSA issued the HM-218H final rule on June 2, 2016, and has yet to make changes to the final rule to provide for a transition period, or explain conditions that may be applicable to the transition, for revisions to nitric acid packaging and emergency response phone numbers as agreed to in letters to petitioners. This hazmat alert reviews questions raised by the delay in finalizing transitional provisions and concerns with two recent interpretations with regard to use of absorbent material for cushioning nitric acid packagings. Transitional Provisions for HM-218H Requirements for Nitric Acid Packaging and Emergency Phone Numbers