By JHMT StaffApril 15, 2020
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On April 7, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Notice of Enforcement Discretion for Cylinders. The notice states that PHMSA will not take enforcement action against any person who fills a DOT-specification cylinder used to transport Division 2.2 non-flammable gas provided the cylinder meets all requirements of the Hazardous Materials Regulations (HMR) except that the cylinder is overdue for periodic requalification by no more than 12 months. View the full notice (PDF).
On April 10, PHMSA issued a notice on HazMat Shipping Paper Requirements and Social Distancing. The notice outlines methods carriers and shippers may follow to satisfy the safety requirements of the HMR while maintaining appropriate social distancing during the COVID-19 public health emergency. View the full notice (PDF).
Also on April 10, PHMSA issued a revised Hand Sanitizer Notice of Enforcement Discretion. This updates the notice provided in HazMat Alert 2020-17 on April 3, 2020 - PHMSA Issues Temporary Policy, Special Permits Responding to the Public Health Emergency. PHMSA issued a Temporary Policy providing relief for the transportation of certain alcohol-based hand sanitizer products, by highway mode only. The guidance was revised to remove the registration requirement regardless of quantity and to to allow the FDA label as an option to PHMSA's text mark if it is visible. View the revised guidance (PDF).
On March 6, the International Air Transport Association (IATA) provided guidance clarifying the requirements to transport infectious substances and hand sanitizer by air. IATA affirms the classification of COVID-19 specimens as UN 3373, Biological substance, Category B. IATA also reminds that alcohol-based hand sanitizers are classified as dangerous goods, and provides specific guidance for the addition of alcohol-based hand sanitizer as aircraft equipment, as well as carriage in passenger and crew baggage. View the full guidance (PDF).
On April 7, Transport Canada created a page on their website to provide guidance for the safe transportation and packaging of infectious substances (Class 6.2), in the particular context of COVID-19. View the full guidance.
Additional Relevant HazMat Alerts:
2020-13 - March 23, 2020 - FMCSA Emergency Declaration Guidance. Many in the regulated community are operating or are looking to operate under exemptions to new restrictive orders put in place by local authorities.
2020-14 - March 25, 2020 - Update: PHMSA Enforcement Policy Notice Regarding Hazardous Materials Training. The notice states that PHMSA has decided to temporarily halt enforcement actions against shippers and carriers that are unable to comply with training requirements included in the Hazardous Materials Regulations (HMR). PHMSA is limiting this relief to recurrent training requirements and it does not apply to all other HMR obligations or applicable laws for hazardous materials offers and carriers.
2020-15 - March 30, 2020 - Transport Canada Issues Temporary Certificates: Training; Testing and inspection requirements. TC issued two temporary certificates providing relief. The first of the two applies to training while the second applies to testing and inspection requirements.