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Archive for the ‘HazMat’ Category

NEW and Greatly Improved DOT Web Site

February 27th, 2018 by Howard Skolnik

Filed under: DOT/UN, HazMat, Industry News, Skolnik Newsletter

The US Department of Transportation (US DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) recently launched their updated website, www.phmsa.dot.gov. And more recently, under the Regulations and Compliance section of the website, PHMSA added a search feature to the Interpretations page, allowing users to filter Hazmat vs. Pipeline Interpretations and sort by key word, topic, or date range. This search feature is located on the left-hand side of the webpage (see image below). Site visitors can now monitor the Hazmat interpretations, and use the new PHMSA Interpretation search for archived letters.

The site offers navigation tabs organized by About PHMSA, Safety, Regulations and Compliance, and Resources. Recourse highlights include Data and Statistics, including HazMat Incident Statistics. Also highlighted are a number of videos emphasizing current HazMat safety Issues.

2018 New Hazmat Rules At-A-Glance

February 22nd, 2018 by Natalie Mueller

Filed under: DOT/UN, HazMat, Industry News

They say the only thing constant is change and that couldn’t ring more true for those of us in the dangerous goods business. As the transportation, manufacturing, chemical and hazmat industries all keep evolving, so too do the regulations that govern them. At Skolnik, we do our due diligence to ensure all of our products meet, if not exceed, the hefty regulatory standards they face. Part of that due diligence is staying on top of changes to the rules and regulations.

In 2018, a few new rules regarding hazmat containers and shipment will hit the books — here’s a quick look at what those regulations, some of which have already taken effect.

Already in effect:

International Air Transport Associations Dangerous Goods Regulations (IATA DGR), 59th Edition – In effect as of 01/01/2018

Changes include:

  • Stricter requirements regarding air-shipment of lithium batteries

  • A re-organized list of Class 9 materials (see Subsection 3.9.1)

  • A new list forecasting changes for air shippers in 2019 (Appenix I).

Furthermore, IATA has already published an addendum to this year’s DGR that impacts air shippers and airline passengers alike, so look for that as well.

2016 International Maritime Dangerous Goods Code (IMDG Code) — Updates in effect as of 01/01/2018

Reinforces updates that were made in the 2016 edition. Compliance to these updates was voluntary last year, as of this year they are officially mandatory.

Rules include:

  • New dangerous goods marking and labeling criteria

  • New packing instructions for certain shipments of engines, lithium batteries and aerosols

  • Adjustments to the IMDG Code Dangerous Goods list

Coming soon:

Enhanced Safety Provisions for Lithium Batteries by Air (RIN 2137-AF20)  — Expected 02/2018

This Interim Final Rule will harmonize the 49 CFR hazmat regulations with evolving international standards for the air shipment of lithium batteries. International requirements already in effect under the latest IATA DGR will be adopted into 49 CFR.

Rules include:

  • Prohibiting lithium-ion cells and batteries as cargo on passenger aircraft

  • Limiting state-of-charge to 30%

  • Limiting the use of alternate provisions for small cells or batteries by air

Response to Industry Petitions (RIN 2137-AF09) — Expected 02/2018

Currently, parties must petition US DOT to amend, remove or add hazmat regulations to enhance safety/efficiency for shippers and carriers. In 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) plans to address 19 of these petitions. This response will likely include new amendments and rules.

 

Miscellaneous Amendments Pertaining to DOT Specification Cylinders (RIN 2137-AE80) — Expected 04/2018

Likewise, DOT will address various petitions from industry stakeholders. These petitions pertain to the manufacture, maintenance and use of DOT specification cylinders. This ruling will incorporate two existing hazmat special permits into the 49 CFR Hazardous Materials Regulations (HMR)

 

EPA’s Electronic Hazardous Waste Manifest System — Roll-out to begin 06/2018

The Hazardous Waste Manifest is a shipping paper required for the transport of hazardous waste, and hazardous waste is regulated in transport by US DOT. While this rulemaking has implications across various industries, here are the consequences specific to hazmat shippers:

The new e-Manifest system will be rolled out on/by June 30th. The EPA plans to utilize the e-Manifest to collect domestic hazardous waste manifests and domestic shipments of State-only regulated hazardous wastes. The e-Manifest system will be funded via user fees for the treatment, storage, and disposal facilities and State-only waste receiving facilities.

Oil Spill Response Plans for High-Hazard Flammable Trains (RIN 2137-AF08) — Expected 07/2018

A Final Rule from DOT to expand the applicability of oil spill response plans for trains transporting Class 3 flammable liquids in specific volumes and orientations across the train. This requirement will apply to High-Hazard Flammable Trains (HHFTs).

These are just the new hazmat rules that are already on the horizon. As always, Skolnik will continue to monitor future regulations or updates that may impact operations, shippers, brokers and carriers, and we encourage all other dangerous goods professionals to do the same.

Doing your due diligence now can prevent a disaster (or hefty fine) later.

What’s News in HazMat Regs?

February 20th, 2018 by Howard Skolnik

Filed under: DOT/UN, HazMat, Industry News, Skolnik Newsletter

It is said that the only thing constant is change, and that couldn’t ring more true for those of us in the dangerous goods business. As the transportation, manufacturing, chemical and hazmat industries all keep evolving, so too do the regulations that govern them. At Skolnik, we do our due diligence to ensure all of our products meet, if not exceed, the hefty regulatory standards they face. Part of that due diligence is staying on top of changes to the rules and regulations.

In 2018, a few new rules regarding hazmat containers and shipment will hit the books — here’s a quick look at what those regulations, some of which have already taken effect.

Already in effect:

International Air Transport Associations Dangerous Goods Regulations (IATA DGR), 59th Edition — In effect as of 01/01/2018. Changes include:

  • Stricter requirements regarding air-shipment of lithium batteries
  • A re-organized list of Class 9 materials (see Subsection 3.9.1)
  • A new list forecasting changes for air shippers in 2019 (Appenix I).

Furthermore, IATA has already published an addendum to this year’s DGR that impacts air shippers and airline passengers alike, so look for that as well.

2016 International Maritime Dangerous Goods Code (IMDG Code) — Updates in effect as of 01/01/2018. Reinforces updates that were made in the 2016 edition. Compliance to these updates was voluntary last year, as of this year they are officially mandatory. Rules include:

  • New dangerous goods marking and labeling criteria
  • New packing instructions for certain shipments of engines, lithium batteries and aerosols
  • Adjustments to the IMDG Code Dangerous Goods list

Coming soon:

Enhanced Safety Provisions for Lithium Batteries by Air (RIN 2137-AF20) — Expected 02/2018.
This Interim Final Rule will harmonize the 49 CFR hazmat regulations with evolving international standards for the air shipment of lithium batteries. International requirements already in effect under the latest IATA DGR will be adopted into 49 CFR. Rules include:

  • Prohibiting lithium-ion cells and batteries as cargo on passenger aircraft
  • Limiting state-of-charge to 30%
  • Limiting the use of alternate provisions for small cells or batteries by air

EPA’s Electronic Hazardous Waste Manifest System — Roll-out to begin 06/2018. The Hazardous Waste Manifest is a shipping paper required for the transport of hazardous waste, and hazardous waste is regulated in transport by US DOT. While this rulemaking has implications across various industries, here are the consequences specific to hazmat shippers:

  • The new e-Manifest system will be rolled out on/by June 30th. The EPA plans to utilize the e-Manifest to collect domestic hazardous waste manifests and domestic shipments of State-only regulated hazardous wastes.
  • The e-Manifest system will be funded via user fees for the treatment, storage, and disposal facilities and State-only waste receiving facilities.

Doing your due diligence now can prevent a disaster, or hefty fine, later.

PHSMA Warns about Refilling Propane Cylinder

January 29th, 2018 by Howard Skolnik

Filed under: DOT/UN, HazMat, Industry News, Safety, Skolnik Newsletter

It has been an extreme winter and PHMSA has recently campaigned for awareness about not refilling certain propane cylinders. To highlight the safety concern,
PHMSA has created a New YouTube Safety Video and Poster cautioning against refilling DOT 39 Cylinders. With safety as its primary mission, the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) produced the following promotional items:

Both promotional pieces target and cautions the public to never refill DOT 39 cylinders, such as the 1lb. cylinders used for camping. While many types of propane cylinders are designed to be refilled, a DOT 39 cylinder of any size is strictly non-refillable. Hazardous materials incidents involving refilled DOT 39 cylinders have been reported and include one fatality. If you have any questions about refilling any cylinder, please contact a qualified refiller, or PHMSA’s HAZMAT Info Center at 1-800-467-4922, https://www.phmsa.dot.gov, or e-mail: infocntr@dot.gov.

—Howard Skolnik

Steel and plastic drums are conventionally sold as new and/or reconditioned from recognized drum manufacturers and distributors. Used primarily to transport dangerous goods (hazmats), it is imperative that if a drum is going to be reused, the contents of the drum must be professionally cleaned according to regulatory and industry standards.

Most recently, Craiglist and Ebay were cited for knowingly selling used drums that have not complied with the reuse regulations. The result is that both sites have created an outlet for drums that could cause fatal injuries and potential explosions. Hundreds, if not thousands, of used and potentially dangerous industrial barrels are listed for sale on Craigslist and other sites where they are advertised as good for everything from rain barrels and trash cans to catfish traps and “smoker” backyard grills. Often, the containers come with a dangerous twisted and torn-off labels making it impossible to identify the previous contents. In most cases, these drums once held toxic chemicals and hazardous, flammable commercial products. The sellers of these drums have no real knowledge of how the drums were previously used and are offering drums that could have contained poisons!

Investigated recently by Rick Barrett of the Milwaukee Journal Sentinel, this dangerous practice is being brought into the public eye with the hope that this illegal practice will cease. Industry officials say they would prefer that used barrels be properly refurbished and reused, or be scrapped, rather than be sold to consumers through unregulated web sales.