Wednesday, June 03, 2020
 
     

IN THIS ISSUE – SEPTEMBER/OCTOBER 2019

PHMSA HM-219C NPRM ON REDUCING REGULATORY BURDENS
PHMSA recently published a notice of proposed rulemaking (NPRM) proposing to adopt over 20 petitions for rulemaking from the regulated community focused on reducing regulatory burdens. Proposed changes address incorporation by reference, special provisions, packaging standards, and others. Review of HM219C 

CLASSIFICATION OF VISCOUS MATERIALS
Whether a material is a liquid or a solid is a key consideration in classifying a material. This article looks at the conditions under which a viscous material may be classified as a solid. When is a viscous material a solid?

REPORT ON THE 37TH SESSION OF THE UNSCEGHS
The GHS Sub-Committee of Experts met in Geneva on July 8-10, 2019 for its 37th session. This report summarizes discussions and papers, including development of a new GHS Chapter 2.1 (explosives), digitalization of hazard information and use of non-animal testing methods.  Report on 37th Session of the UN GHS Sub-Committee Meeting                                                                                    

REGULATION OF SECURITY-SENSITIVE HAZARDOUS MATERIALS
A company is required to maintain a written transportation security policy and asks the Journal for a summary of government authorities regulating security-sensitive hazardous materials. Transportation Security Policy 

LIMITS FOR ARTICLES UNDER MOTS PROVISIONS
Packing group (PG) assignments for articles were removed in HM-215M. Under § 173.6, gross mass and capacity limits for materials of trade (MOTs) are specified according to PG. Since articles are not assigned packing groups, it is not clear whether articles are eligible for MOTS or what gross mass limits apply if they are. A recent PHMSA interpretation and a preceding article in the Journal are reviewed. Use of MOTS Provisions for Articles

ROLLING HOOPS ON STEEL DRUMS
This article looks at provisions for rolling hoops for steel drums under Canadian standards in comparison to provisions in the HMR, the UN Model Regulations, the IMDG Code and the ICAO Technical Instructions. The Canadian standards require rolling hoops whereas the other standards permit them but do not require them. Requirements for Rolling Hoops on Steel Drums

USE OF METAL IBCS FOR PG I MATERIALS
This article looks at potential impacts and considerations of a proposal to amend the UN Model Regulations to authorize PG I liquids that have historically not been allowed in IBCs. Proposed UN Authorization for Packing Group I Liquids in Metal IBCs

UPDATE TO TRANSPORT CANADA STANDARD TP14850
This review of the update to TP14850,"Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8 and 9, a Transport Canada Standard," looks at the use of recycled plastics, requirements for rolling hoops on metal drums and periodic retests. Canadian Regulations 

NFPA 30 FIRE SAFETY CODE  
This article provides an overview of THE NFPA 30 Flammable and Combustible Liquids Code addressing flammability and combustibility definitions, compliant packaging and costs of non-compliance. NFPA 30 Flammable and Combustible Liquids Code Compliance

ISSUES CONCERNING EXPORT OF STEEL DRUMS
Guidance is provided on issues faced by shippers using steel drums for exports, such as whether the UN drums have been approved by the US government; whether the required embossed mark on the bottom must be complete; and how the UN mark must be applied to the drum. Issues that May be Raised Concerning Steel Drums

VENTING OF PACKAGINGS
Venting options for both pressure relief and vacuum relief are discussed in this overview which covers packaging strength, materials of construction, chemistry of packaged materials, manner of filling, applicable regulations and types of vents. Venting Options for Packagings and IBCs

USE OF RECYCLED PLASTICS IN IBC INNER RECEPTACLES
This article reviews some of the history of using recycled plastics, the benefits provided through reducing plastics wastes, and a proposal to amend the UN Model Regulations to allow recycled plastics for IBC inner receptacles. Proposed ICPP Paper on the Authorization for Recycled Plastics in IBC Inner Receptacles

COMMENTS ON DOT INTERPRETATIONS
Comments are provided on recent interpretations from DOT concerning packaging requirements applicable to deuterium and transport of internationally regulated environmental substances which are not regulated under the HMR. COMMENTS ON DOT INTERPRETATIONS

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