Monday, October 19, 2020

The Journal of HazMat Transportation

A Publication of PRI International, Inc.

Volume 31, Number 3 September/October 2020

In This Issue    

PHMSA Penalties:  July and August 2020

DOT Rule and Rulemaking Summary   

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


Discussions on Recent PHMSA Interpretations

  • Quality Assurance Program
  • Explosives in Refrigerated Containers
  • Research, Development and Testing Equipment Aboard Cargo Aircraft
  • Cryogenic Liquids Exceptions
  • Small Cell and Battery exceptions

By Christopher Lind, Technical Advisor

PHMSA Rules / Rulemaking Reports

A Review of PHMSA’s Rulemaking Agenda: Update
By Ed Mazzullo, Technical Advisor 

The regulatory clock keeps ticking, and this article reviews regulatory initiatives both underway and anticipated at PHMSA. Regulatory actions are grouped by subject matter. A careful review is suggested, as much remains to be accomplished.

PHMSA Special Permits

A Review of Select Special Permits Granted in August 2020  
By Christopher Lind, Technical Advisor

Covering special permits granted during August 2020, Mr. Lind selects nine of particular importance to highlight and discuss. The permits themselves can be found by reporting this report on

Dangerous Goods by Air

ICAO and IATA Changes for 2021
By Patrick Oppenheimer, Technical Advisor

Mr. Oppenheimer reviews the work and discussions at the most recent Twenty-Seventh International Civil Aviation Organization Dangerous Goods Panel (ICAO DGP) meeting which took place in Montreal in September 2019. This report also provides an outline of changes to the International Air Transport Association's changes to the 2021 Dangerous Goods Regulations.

Dangerous Goods Training

Competency Based Training: Does It Make Sense     
By Christopher Lind, Technical Advisor

This report puts together important pieces of the training "big picture:" requirements for hazmat employee training; definition of a hazmat employee; and competency based training as discussed at the UN Sub-Committee, ICAO TI, and PHMSA. PHMSA did not address CBT in its HM-215O harmonization final rule.

Legislative Reports

FY 2021 – Funding for PHMSA’s HazMat Transportation Programs Advances in the House and Stalls in the Senate
By Cynthia Hilton, Legislative Advisor

In this updated report (original version issued in HazMat Alert 2020-49), we dive once more into funding legislation and recommendations. Ms. Hilton's report supplies detailed information regarding appropriations for OHMS; emergency preparedness grant programs; PHMSA HQ requests; the extension of the HMTA; and next steps to look forward to.

Storage of Regulated Materials

Alcohol Based Sanitizers are Flammable Materials    
By Christopher Lind, Technical Advisor

Mr. Lind provides this timely report reviewing the chemical and physical characteristics of alcohol-based sanitizers as well as classifications of sanitizer solutions. Included is practical advice and suggestions to avoid compliance complacency, and complying with specific OSHA and NFPA 30 provisions.

Dangerous Goods Packaging

Dry Ice Replenishment by Freight Forwarders or Airlines of Packages When In Transportation   
By Christopher Lind, Technical Advisor

An inquiry came in involving five scenarios for an airline, DG Certified company, or freight forwarder who opened packages of non-regulated materials in non-specification packagings and regulated materials in non-specification or UN Standard Packagings. The Journal requests further reader input on this subject.


The European Union CLP Classification as it Relates to Transport   
By Frits Wybenga, Senior Technical Advisor

A reader asks what to do when classifications do not agree? Mr. Wybenga responds in detail to address a circumstance whereby a European “Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures” classification disagrees with specific toxicity data for the substance that would cause it to not be classified.

Classification of Environmentally Hazardous Mixtures
By Rick Bornhorst, Technical Advisor

In the context of the required well-established use of UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS) criteria for classifying environmentally hazardous materials (EHS), Mr. Bornhorst provides a practical review of varying EHS systems for the classification of mixtures. He also addresses the complex situations where carriers might sometimes reject shipper classifications.

The IMDG Code Criteria for Classifying Environmentally Hazardous Substances: Part I    & Part II           
By Frits Wybenga, Senior Technical Advisor

In celebration of The Journal’s 30th year of publishing we are pleased to present as a first in our new “best of” series, a report by Frits Wybenga. All those concerned with classification of materials will find these reports essential, particularly first time readers. This report is immediately followed by his Part II presentation on the same subject of criteria for environmentally hazardous substances in the IMDG Code.

Reader Question: Self-Reactive Materials  
By Frits Wybenga, Senior Technical Advisor

Mr. Wybenga guides a reader through the hard-to-navigate waters of self-reactive material classification. His report goes through the background of self-reactive substances, self accelerating decomposition temperature, polymerizing substances, test methods, and lastly, provides an answer to the query.


Special Permits and the Potential Responsibility of Entities "Using" Contractors  
By Christopher Lind, Technical Advisor

A reader inquires regarding a situation in which a hazardous waste contractor is contracted to collect, classify, package, mark, label, fill out shipping papers, and transport a material for appropriate disposal, covered by a Special Permit. Mr. Lind provides guidance on the topic of "hazmat employers."

Marine Pollutant Marks 
By Christopher Lind, Technical Advisor

A Journal subscriber writes in asking for clarification or opinion on the Marine Pollutant marks and references to any supporting DOT Interpretations; Mr. Lind replies with abundant citations.

Transportation Risk Management

Evaluating Risk Reduction Options including a discussion on Risk Management vs. Risk Elimination: Part 5 (Final Segment) of a Series       
By Cherry Burke, PhD, Technical Advisor

In the fifth and final part of her series thoroughly covering transportation risk management, Dr. Burke concludes with vital coverage of risk reduction options as well as the essential task of distinguishing between risk management and risk elimination – and the potential shortfalls of unrealistic expectations for the latter.

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 Different Packaging 178.601(c)(4)(ii).;
  • Meaning of visual inspection and qualifications for performing a visual inspection by tank car facilities


U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations: June, July, August, and September 2020. 15 letters sorted, indexed and provided verbatim.

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