U.S. Regulations articles

USDOT/PHMSA formalizes requirements for “Reverse Logistics”

USDOT/PHMSA formalizes requirements for “Reverse Logistics”

In today’s edition of the US Federal Register, the United States Department of Transportation’s (USDOT) Pipeline & Hazardous Materials Safety Administration (PHMSA) published a final rule under Docket # PHMSA-2011-0143 (HM-253), RIN 2137-AE82 under which the agency sets forth specific rules to regulate the transport of materials under the so-called “Reverse Logistics” principle.  This function

FAA Reauthorization Legislation Focused on Lithium Batteries

Bob Richard and Neil McCulloch co-contributed to this article.  When a US Senator proposes to spend tax dollars on a committee to “promote research and new standards for the safe manufacture, use or transportation of lithium batteries,” I can only sigh in frustration. This is exactly what was recently proposed by Sen. Bill Nelson, D-Fla.. 

Federal Register publishes HM-233F revisions to the HMR

The United States Department of Transportation’s (USDOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) yesterday published the newest rulemaking under its HM-233 Docket family.  This incorporates various aspects of previously issued Special Permits (SP’s) into the body of the regulations.  Specials Permits are administrative actions that grant specific users permission to do something outside of

New Year, New Revisions to DG Regulations for IATA and IMO

As often occurs at the turn of the year, both the International Maritime Organization (IMO) and the International Air Transport Association (IATA) have released updates to their respective Dangerous Goods Regulations.  In the case of the IATA regulations, much of it has to do with revisions to rules surrounding lithium batteries.  Please see our relevant

DG Digest: FMCSA lowers truckers’ substance test rates, will hold FAST sessions; FRA begins PTC data collection

December 24: FMCSA cuts random truckers’ testing rate for substance abuse to 25%. Good news for truck drivers and carriers—the United States Department of Transportation’s (USDOT) Federal Motor Carrier Safety Administration (FMCSA) has cut the random testing rate for substance abuse in half, from 50% to 25%. This should produce a nice savings for carriers,

OSHA finds non-consumer lithium batteries subject to the 2012 HCS

In what one can only characterize as a remarkable development for American manufacturers and importers, on December 17th the US Department of Labor’s (USDOL) Occupational Safety and Health Administration (OSHA) issued a formal Letter of Interpretation in response to a query regarding their consideration of the status of Lithium batteries as articles (or not).  The

USDOT/FMCSA announces delay to new Medical Exam Report and Certificate compliance date

Today the United States Department of Transportation’s (USDOT) Federal Motor Carrier Safety Administration (FMCSA) formally made the anticipated announcement of which rumor had circulated in the regulatory community for the last several days.  FMCSA offered a “grace period” of 120 days regarding mandatory use of the new Medical Examination Report (MER) (Federal Form MCSA-5875) and

The Latest Developments in International DG Regulations

It’s been an incredibly busy last six weeks in the realm of international regulatory development. The beginning of November saw the ICAO Dangerous Goods Panel wrap up its 24th biennium, putting the final changes in place for the 2017-2018 ICAO Technical Instructions and tackling the very difficult subject of whether or not a prohibition on lithium batteries

Are There New FMCSA Electronic Logging Devices Regulations on the Horizon?

The Federal Motor Carrier Safety Administration (FMCSA) submitted a notice of filing on December 10, 2015, that will mandate the use of electronic logging devices (ELDs) by interstate commercial motor vehicle drivers who currently use a driver’s log to record their hours of service.  This ruling is scheduled to be posted in the Federal Register

New OSHA Letter of Interpretation clarifies Import/Export issues under the HCS

On November 23rd, 2015 the Occupational Safety & Health Administration (OSHA) released a Letter of Interpretation (LOI) which offered further clarification of US companies’ responsibilities when importing or exporting materials which require action under the 29 CFR 1910.1200 Hazard Communication Standard (HCS).  This standard was revised in 2012 to harmonize it with the UN Globally

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