Monday, October 26, 2020
 
     

IN THIS ISSUE – MARCH/APRIL 2019

EXPIRED POLYMERIZING SUBSTANCE PROVISIONS RAISE CONCERNS
Certain requirements for polymerizing substances expired on January 2, 2019, but according to the HM-215O NPRM, PHMSA intends to extend them. How will this affect global shippers in the interim? Difficulties with Compliance Dates and Requirements for Shippers of Polymerizing Substances

EPA IGNITABLE GAS CHARACTERISTIC
In the third installment of a series reviewing differences between EPA hazardous waste criteria and DOT classification criteria, this article reviews the EPA ignitable gas characteristic and its relationship to the DOT Division 2.1 criteria for flammable gases, with a focus on defining criteria, test methods, and exceptions. The EPA Ignitable Gas Characteristic and Its Relationship to the DOT Division 2.1 Criteria

HOT TOPICS IN COMMENTS TO THE HM-215O NPRM
As we await the issuance of a final rule following the HM-215O International Harmonization notice of proposed rulemaking (NPRM) issued November 27, 2018, we look at significant comments to the NPRM concerning proposed amendments to provisions for polymerizing substances, harmonization with Transport Canada, and provisions for a new lithium battery test report summary; and comments to PHMSA’s request for input on a competency-based approach to training. Significant Topics Addressed in Comments to the HM-215O International Harmonization Notice of Proposed Rulemaking

RECOVERING HDPE FROM INDUSTRIAL PACKAGINGS
In the interest of corporate responsibility to the environment, companies are striving to reduce, reuse, and recycle wherever practicable. This article examines the recovery of Post-Consumer Resin (PCR), by reclaiming high-density polyethylene (HDPE) from recollected industrial packaging. Sustainable Packaging and the Case for PCR 

REPORT ON THE 51ST THRU 54th SESSION OF THE UNSCETDG
Based on results of the last four meetings (51st thru 54th sessions) of the UN Sub-Committee of Experts on the Transport of Dangerous Goods (UNSCETDG) over the last biennium, the UN secretariat will now produce the 21st edition of the UN Model Regulations (UNMR) and an addendum to the UN Manual (7th edition). In two parts, this report focuses on the combined efforts of the four meetings. Results of 51st through 54th Sessions of the UNSCETDG: Part 1 and Part 2

PHMSA ISSUES RAIL RESPONSE PLANNING AND INFO SHARING FINAL RULE
The HM-251B final rule, developed in coordination with the FRA, puts in place requirements for oil spill response planning and information sharing for high-hazard flammable trains. It is intended to improve oil spill response readiness and mitigate effects of rail accidents and incidents involving petroleum oil and high-hazard flammable trains (HHFTs). PHMSA Issues HM-251B Final Rule for Oil Spill Response Plans and Information Sharing for High-Hazard Flammable Trains=

RISK MANAGEMENT SYSTEM—BASIC COMPONENTS
In this article, the second in a series, the author examines the basic components of a transportation risk management system, focusing on Regulatory Compliance and Company Standards/Requirements.  Risk Prioritization, Risk Assessment, and Risk Reduction will be explored in future articles. Components of a Comprehensive Transportation Risk Management System=

“EMPTY” CONTAINERS UNDER EPA RULES
This article examines the history and practical application of EPA “empty” container rules and explains the important economic and environmental benefits it provides to manufacturers doing business in the United States. A Discussion of the Federal EPA Empty Container Rule: Purpose and Application=

PHMSA RULES AGENDA 2018/2019
PHMSA’s rulemaking actions completed in 2018 and early 2019, and the agency’s regulatory agenda plans for the remainder of 2019 are reviewed. Part A covers rulemaking actions (notices and final rules) completed in 2018; Part B look at rulemakings issued in early 2019 and PHMSA’s regulatory agenda for the remainder of 2019. PHMSA Regulatory Review: Part A--Rulemaking Planning and Accomplishments for 2018; Part B—Review/Preview of 2019 Rulemaking Actions, 

COMMENTS ON DOT LETTERS OF INTERPRETATION
Comments are provided on recent interpretations from DOT concerning the assignment of articles to UN3268 Safety Device, electrically initiated under §173.166.  Comments on DOT Interpretations

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