IN THIS ISSUE – JANUARY/FEBRUARY 2019
Intermediate Bulk Container Primer
This article is a primer on the most common types of intermediate bulk containers, their nomenclature and capabilities, and offers guidance to selecting the appropriate IBC. Best Practices for Intermediate Bulk Containers.
EPA IGNITABLE/DOT FLAMMABLE SOLIDS
Differences between EPA hazardous waste criteria for ignitable solids and DOT criteria for flammable solids are reviewed in this article, with a focus on defining criteria, test methods, and exceptions. The Marriage of EPA Characteristic Criteria and DOT Hazard Class Defining Criteria – Session 2.
HM-215O INTERNATIONAL HARMONIZATION NPRM
On November 27, 2018, PHMSA issued a long-awaited notice of proposed rulemaking (NPRM) in the Federal Register concerning harmonization with international standards [Docket No. PHMSA-2017-0108(HM-215O)]. The NPRM proposes to align DOT’s Hazardous Materials Regulations (HMR) with recent changes to international regulations and standards, such as the 20th Revised Edition of the United Nations Recommendations on the Transport of Dangerous Goods (UN Model Regulations). This report reviews the extensive changes proposed in the NPRM, and was published on the hazmatship.com website as HazMat Alert 2018-35. PHMSA Issues the HM-215O International Harmonization NPRM.
SAFETY MANAGEMENT SYSTEMS
This article provides insights into improving the safety performance and culture of your organization and enhancing business practices and operations through adoption of a Safety Management System (SMS) approach. Charting a New Path with SMS
REPORT ON THE 54TH SESSION OF THE UNSCETDG
From November 26 – December 5, 2018, the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods (SCETDG) held its 54th session in Geneva, Switzerland. The SCETDG agenda addressed 58 formal proposals (working papers) in 8 general topic areas as well as 54 informal (INF) papers in the fourth and final session of the biennium, resulting in changes for the 21st revised edition of the UN Model Regulations. Report on Proposals discussed at the 54th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods.
REPORT ON THE 36TH SESSION OF THE UNSCEGHS
The United Nations Globally Harmonized System of Classification and Labeling of Chemicals Sub-Committee (UNSCEGHS) met in Geneva on December 5 - 7, 2018 for the 36th session and fourth session of the 2017-2018 biennium, resulting in the 8th revision to the GHS. This report covers the issues addressed at the session. Report on 36th Session of the UN GHS Sub-Committee Meeting.
COMMENTS ON PHMSA INTERPRETATION ON RAIL TANK CAR PACKAGING COMPONENTS
In this article, the author sets forth concerns about a recent PHMSA interpretation (DOT reference No. 18-0029) addressing application of the HMR to rail tank car “packaging components” and potential impacts on “tank car facilities”. Comments on PHMSA Interpretation 18-0029 Concerning Packaging Components of Rail Tank Cars.
PETITIONS FOR RULEMAKING
Two recent petitions for rulemaking may be of interest to readers. In P-1720, Hazmat Safety Consulting requests PHMSA amend the HMR to allow for certain packagings manufactured outside the U.S. to be marked “USA”. [See Comments on PHMSA Interpretation 18-0108.) Petition Number P-1723]. Page 20. In Petition P-1723, the International Vessel Operators Dangerous Goods Association (IVODGA) requests PHMSA amend § 176.30(a) of the HMR to allow the Dangerous Cargo Manifest Ito be maintained electronically aboard a vessel. RECENT PETITIONS FOR RULEMAKING.
CERTIFICATION OF TANK CAR FACILITIES
The Association of American Railroads has revised certain definitions and AAR facility certification requirements contained within the AAR’s Manual of Standards and Recommended Practices, Section C, Part III, Specifications for Tank Cars. The proposed changes, as implemented, will significantly increase the number of facilities that require an AAR-approved quality assurance program and AAR facility certification. AAR Final Action: Certification of Tank Car Facilities.
COMMENTS ON DOT LETTERS OF INTERPRETATION
Comments are provided on recent interpretations from DOT concerning certification of foreign UN packagings by U.S. third party labs, classification of a mixture containing a named hazardous material, and the level of detail necessary to satisfy function-specific training requirements of the HMR. Comments on DOT Interpretations.