Monday, July 06, 2020

The Journal of HazMat Transportation

A Publication of PRI International, Inc.

Volume 31, Number 1 May/June 2020

In This Issue                                                              

PHMSA Penalties:  March and April 2020      

DOT Rule and Rulemaking Summary 

Compliance Dates: Login to and find links to these resource under Critical Dates in the top navigation bar.                    


  • Exceptions for passengers, crewmembers, and air operators. Lithium battery Operated Assisted Mobility Devices
  • Placarding Requirements and Visibility
  • HazMat Transportation Guidance
  • Empty Packagings
  • Selective Testing
  • Prohibited Labeling and Permitted and Prohibited Placarding

By Christopher Lind, Technical Advisor

Rules and Rulemaking Reports

Part 1: PHMSA Issues the HM-215O International Harmonization Final Rule  
By Christopher Lind, Technical Advisor   

Part one of Mr. Lind's report on Final Rule HM-215O covers the following sections: Provisions for Polymerizing Substances; Incorporation by Reference; Definitional Changes; Harmonization with Canadian Regulations; Hazardous Materials Table (§ 172.101) and Special Provisions; Articles containing dangerous goods; and Hazard Communication.

Part 2: PHMSA Issues the HM-215O International Harmonization Final Rule 
By Christopher Lind, Technical Advisor  

Part two covers the following sections: Lithium Battery Provisions; Packaging Provisions; Alternative criteria for classification of corrosive materials; Vessel Provisions; Packaging Test Provisions; and International Changes Not Being Adopted.

Dangerous Goods by Air

An International Air Transport Case Study 
By Frits Wybenga, Senior Technical Advisor

Mr. Wybenga examines real-world issues with an international air shipment in packagings authorized by the U.S. Competent Authority. He provides some advice regarding packagings authorized under 173.24a(b)(3). 

Dangerous Goods Packaging

Temperature and Shock Monitors for Shipping Containers
By Christopher Lind, Technical Advisor

Mr. Lind provides a useful reference and summary of monitoring and recording devices with this report on the use and advantages of temperature and shock monitors.

Packaging Selection for High Vapor Pressure Liquid Materials
By Christopher Lind, Technical Advisor

This report offers a look at high vapor pressure materials as well as offering guidance on determination, packaging selection, and the differences between packaging choices.

HazMat Training

Best Practices and Training
By Patrick Oppenheimer, Technical Advisor

Read this for a focus on best practices for shipping hazardous materials safely, in particular as pertains to compliance with air regulations. Mr. Oppenheimer covers training requirements, record-keeping requirements, and suggests some training recommendation and best practices.

UN Reports

Part 1: Pre-Meeting Report on Proposals to be Discussed at the 57th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods  
By Christopher Lind, Technical Advisor

In Mr. Lind's UN pre-meeting report, we provide brief summaries of each proposal submitted to the upcoming session of the UN SCETDG. Part one looks at the following agenda sections: Explosives and related matters; Listing, classification, and packing; and Electric storage systems.

Part 2: Pre-Meeting Report on Proposals to be Discussed at the 57th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods
By Christopher Lind, Technical Advisor

Part two of Mr. Lind's review of documents submitted to the upcoming UN SCETDG looks at the following agenda sections: Transport of gases; Miscellaneous Proposals for Amendments; Global harmonization of transport of dangerous goods regulations with the Model Regulations; Cooperation with the International Atomic Energy Agency; Guiding Principles; and Issues relating to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Dangerous Goods by Rail

PHMSA Authorizes Electronic Shipping Papers for Rail Transportation 
Richard Bornhorst, Technical Advisor

PHMSA's issuance of a special permit authorizing “the use of electronic means to maintain and communicate on-board train consist and shipping paper information in lieu of paper documentation when hazardous materials are transported by rail” raises interesting questions for the implementation of electronic shipping papers in the future.

Hazard Communication

Using a Safety Data Sheet for Classification of Hazardous Materials
By Christopher Lind, Technical Advisor

Inspired by feedback to The Journal's most recent email survey, Technical Advisor Chris Lind gives thorough coverage of the various aspects and intricacies of classification and safety data sheets.

Lithium Batteries

Shipping Active Data Loggers 
By Patrick Oppenheimer, Technical Advisor

This report provides clarification to a reader inquiring as to the provisions of air transportation regulations when offering commodities of dry ice or other hazardous materials where a temperature recorder powered by “coin cell” lithium metal batteries meets the definition of UN 3091, Lithium batteries contained in equipment.

Comments on DOT Interpretations    

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

  • Meaning of visual inspection and qualifications for performing a visual inspection by tank car facilities
  • Meaning of Gross Weight of Hazardous Material
  • Meaning of the Proper Shipping Name Perfumery Products


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: March, April, and May 2020. 26 letters sorted, indexed and provided verbatim.

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