Monday, October 26, 2020


NTSB Call for Change to ICAO LithBatt Testing Exemption
NTSB has called on the Pipeline and Hazardous Materials Safety Administration (PHMSA) to propose a change to International Civil Aviation Organization (ICAO) requirements that would result in stricter regulation of low-production and prototype batteries transported by air.

Classification on the Basis of Human Experience
Frits Wybenga notes in commenting on a recent letter of interpretation:Clearly there is no escaping the human experience classification in the case of pure substances; but at what point can the human experience classification be discounted in the case of a mixture?” 

Review of New Special Permits
As a part of The Journal’s new ongoing service: Several new special permits granted by PHMSA are presented and reviewed by Chris Lind covering Lithium Batteries, Sanitizing Solutions, Chlorine, Opening of Packages, and Stainless Steel IBCs for High Pressure PGII Liquids.

Conducting a Transportation Risk Assessment
This part 4 presentation by Cherry Burke on risk assessment provides a detailed approach to understanding and formally appraising risks in the supply chain, from the establishment of protocols, creation of a review process, to team creation.

Marine Pollutant Shipment Exceptions
In response to a reader’s question regarding a cargo acceptance issue that arose with a Class 9 shipment, the author provides a detailed review of marine pollutant exceptions as they relate to highway transportation. The impending question of whether it is permissible to offer packages that are marked and labelled as dangerous goods without providing a shipping paper describing the materials in accordance with the regulations is also addressed. 

Requirements for Shipping Empty IBCs
Must a facility offering an “empty” IBC register its site with the U.S. DOT?  A summary of requirements associated with transporting these units as empty and they might affect shipper registration is discussed.

Assignment of Packing Groups for Corrosive Materials
A reader notes that 173.137 defines PGIII metal corrosivity by an annual corrosion rate but also expresses the testing may be done in accordance with UN Manual of TC. The UN MTC describes the same annual rate but adds a localized corrosion (pitting) rate.  Both U.S. and international considerations are examined.

Overlap of U.S. and International Regulations Relative to PIH Materials
The author notes that IATA and IMDG follow the syntax of the UN Model Regulations more closely than the HMR in 49 CFR.  But the 49 CFR add levels of toxicity and inhalation hazards that are silent in international and modal regulations. 

Shipping Stock Absorbing Devices
A reader recently asked for advice on shipping shock absorbing devices in accordance with the HMR and international regulations.  Can transportation occur in this example without an approval under the HMR or an exemption under international regulations?  Looking at this case may prove instructive when shipping other similar devices.

HMTA Reauthorization Legislation Passes in the House
Cynthia Hilton provides a detailed review of H.R.-2, introduced by the House Transportation and Infrastructure subcommittee, and passed  by the House of Representatives.  The biggest issues: lithium batteries and transportation of LNG by railcar. H.R.-2 has been sent to the Senate where its future is uncertain but will certainly be considered in a final bill.

UN TDG Pre-Meeting Report on the 57th Session
We have updated our previous report issued in our May/June 2020 edition based on vitual meetings conducted  by the UNCOE and PHMSA.

UN Globally Harmonized System of Classification
In HazMat Alert, 2020-38, we issued a premeeting review of proposals to be addressed at the 39th Sesseion of the UN GHS Subcommittee.  That report is presented in this issue. 

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