Monday, October 19, 2020
 
     

IN THIS ISSUE – MAY/JUNE 2019

PHMSA FY2020 BUDGET WOES

This report examines the President’s FY 2020 budget request proposing reductions in budget authority for the DOT, including the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Office of Hazardous Materials Safety. The Pipeline and Hazardous Materials Safety Administration’s Fiscal Year 2020 Budget Request – “Dead on Arrival”

CLOSING INSTRUCTIONS OVERVIEW

This article examines the requirements for closing instructions, responsibilities for developing and complying with them, guidance on the dos and donts of package closure and other useful information. The Importance of Closing Instructions

CLASSIFICATION OF SOLID MATERIAL COMBINED WITH LIQUID

This article responds to a reader’s inquiry concerning the classification and packaging of a non-hazardous solid mixed with an environmentally hazardous liquid substance. Classification of a Non-Hazardous Solid Combined with an Environmentally Hazardous Liquid

TAKING AIM AT GUIDANCE MATERIAL

The White House Office of Management and Budget is using the Congressional Review Act to restrain the autonomy and ability of agencies to take a wide range of regulatory actions. As a result, DOT and PHMSA are less likely to issue “major” rules or guidance material and interpretations and may be less capable of responding to new requests for regulatory action and guidance. OMB Memorandum Takes Aim at Guidance Material under the Congressional Review Act

COMMENTS ON A DOT INTERPRETATION

PHMSA interpretation number 18-0128 concerns freight containers with removable (portable) tops. While the question raised relates to radioactive materials transported by vessel in freight containers, PHMSA’s response may also be relevant to the transport of dangerous goods of other classes in bulk in freight containers, particularly under the IMDG Code. Definition of a closed freight container

REPORT ON THE 33rd THRU 36th SESSION OF THE UNSCEGHS

Based on results of the 33rd thru 36 sessions of the UN Sub-Committee of Experts on the Globally Harmonized System of Classification and Labeling of Chemicals over the last biennium, the UN secretariat will now produce the 8th revised edition of the GHS (Purple Book) incorporating the adopted changes. This report summarizes changes adopted during the biennium.  Results of 33rd through 36th Sessions of the UNSCEGHS

COMBINATION PACKAGINGS TESTED FOR LIQUIDS BUT USED FOR SOLIDS

A reader requests help in understanding new provisions in 173.24a for packaging solid materials in combination packagings tested and marked for liquids. May a combination packaging tested with liquids be used for packaging solids?

PRE-MEETING REPORT ON PROPOSALS FOR THE 55TH SESSION OF THE UNSCETDG

The UN Sub-Committee of Experts on the Transport of Dangerous Goods will hold its 55th session in Geneva, Switzerland from July 1 - 5, 2019. The SCETDG agenda will address 37 formal proposals and at least 7 informal (INF) papers. Brief summaries of each proposal are provided, grouped by subject area. Pre-Meeting Report on Proposals to be Discussed at the 55th Session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods

IMPROVING HAZARD CLASSIFICATION FOR EQUIPMENT AND OTHER ARTICLES

In this article, the author suggests a collaborative approach to developing new article classification approaches that are practical, preserve safety, and accurately communicate transportation hazards. The Art of Hazard Classification and Communication

LIMITED QUANTITY ON A SHIPPING PAPER

A reader describes a scenario in which a shipment is refused because a Limited Quantity is described on the shipping paper with other hazardous materials, on the basis that the Limited Quantity entry may cause confusion and delays. The offeror asks our input on describing a Limited Quantity on the shipping paper for transportation by highway only. Shipment Refused Because Offeror Included Limited Quantities on Shipping Paper

COMMENTS ON DOT LETTERS OF INTERPRETATION

Comments are provided on recent interpretations from DOT concerning the display of specification markings on packagings used for non-hazardous materials and marking packages of lithium batteries packed in equipment.  Comments on DOT Interpretations

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