Monday, October 26, 2020
 
     

IN THIS ISSUE – JULY/AUGUST 2019

PROVISIONS FOR ABSORBENT MATERIAL

A reader asks why absorbency requirements are expressly spelled out for excepted quantities and UN3316, but not for limited quantities and other hazardous materials. Differing Requirements for Absorbent Material

ELECTRONIC SHIPPING PAPERS

This article reports on current initiatives focused on electronic shipping papers, including a recent informal submission (INF.16) to the UN Sub-Committee of Experts on the Transport of Dangerous Goods, put forward by the United States and Canada. The joint paper proposes a global collaboration and testing of “innovative ideas” to help identify viable options for allowing electronic shipping papers in lieu of paper documentation.. E-Shipping Papers 2.0

CLASSIFYING METHANOL BASED ON HUMAN EXPERIENCE

In DOT letter of interpretation Ref. No. 16-0116, DOT is asked a series of questions regarding classification on the basis of human experience with a particular focus on methanol. Classification of substances on the basis of human experience poses problems in classifying solutions that contain them and the regulations are deficient in terms of how to address such classifications.  In this article, Senior Technical Advisor Frits Wybenga provides a comprehensive overview of the issues involved. Classification Based on Human Experience

USE OF UN PACKAGINGS

This article examines a DOT letter of interpretation (Ref. N. 18-0063) responding to questions concerning an out-of-compliance certification marking on a bulk UN package and use of specification non-bulk packagings for a material not subject to the HMR. Use of Specification Packagings for Unregulated Materials

PERMISSIVE MARKING AND LABELING

A reader asks for clarification on whether non-bulk packages containing marine pollutants excepted from regulation under § 171.4 may be marked with the Marine Pollutant mark and labeled with a Class 9 label, and be transported without the need for a hazardous materials shipping paper for domestic transportation. Permissive Marking and Labeling of Class 9 Marine Pollutants

RESULTS OF THE 55th SESSION OF THE UNSCETDG

The UN Sub-Committee of Experts on the Transport of Dangerous Goods held its 55th session in Geneva, Switzerland from July 1 - 5, 2019. Thirty-eight (38) working documents and 56 Informal Documents were discussed in plenary and in three working groups on Explosives, Fibre Reinforced Plastic Tanks, and Lithium Batteries. Report on the 55th Session of the UNSCETDG  

FUNDING PHMSA’S HAZMAT PROGRAMS

The Administration’s March 2019 budget request (BR) for PHMSA’s Office of Hazardous Materials Safety represented a nine percent cut over the agency’s final fiscal year (FY) 2019 appropriation. This article reviews the current status of funding for the PHMSA’s hazmat programs. FY 2020 HazMat Appropriations Bill Advances

IBCS INTENDED FOR LIQUIDS USED FOR SOLIDS

This article looks at the use of a “liquid rated” composite IBC (i.e., one intended and tested for liquids) such as a 31HA1 for packaging UN1727, a PG II corrosive solid, as authorized under the provisions of the Hazardous Materials Regulations (HMR). It covers packaging provisions under Special Provision IB8 for IBCs and the need for caution in the filling and emptying of IBCs used for the solid materials. Use of Liquid Rated IBCs for Hazardous Solids

MARKING PROVISIONS FOR CLASS 7 LIMITED QUANTITIES

This article reviews a DOT letter of interpretation, Ref. No. 18-0027, addressed to requirements for the size of the identification number marking on a package containing a Class 7 limited quantity radioactive material and marking requirements for a shrink wrap overpack containing such packages. Did DOT get it right? Review of Marking Requirements for Class 7 Limited Quantities

PHMSA RULES UPDATE

PHMSA’s regulatory agenda is updated to include recent changes focused on regulatory reform initiatives and reducing unnecessary burdens as reported in the Office of Management and Budget’s Spring 2019 Unified Agenda of Regulatory and Deregulatory Actions and recent Federal Register publications. PHMSA Rulemaking Agenda Update

COMMENTS ON DOT LETTERS OF INTERPRETATION

Comments are provided on recent interpretations from DOT concerning molten sulfur residues on rail tank cars and certification marking of incomplete packagings. Comments on DOT Interpretations

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