DG Digest: PHMSA aligns with ICAO & IMO on 2mm inner border issue for labels

The FRA published a proposal to revise its collection of data on Positive Train Control (PTC) implementation on the nation’s railroad network. Operating on trackage rights, a Palouse River & Coulee City short line train rolls over the Union Pacific’s Joso Viaduct crossing the Snake River in remote southeastern Washington State on Saturday, May 12th, 2018. Photo © 5/2018 by Nikki Burgess; all rights reserved.

May proceeds with a little more action on the regulatory front, with PHMSA contributing guidance on the always confusing label border issue and the FRA updating PTC progress. Here’s all the latest:


  • The agency published a Letter of Interpretation clarifying the “2mm inner border” issue for labels in 49 CFR 172.407(c)(3). PHMSA said that they agree with ICAO and the IMO and will rescind this minimum width requirement (but not the requirement to have an inner border!) in upcoming rulemakings.  The required minimum has been causing trouble for some shippers, with otherwise fully compliant packages being rejected on account of differing interpretations of the measurement. See the letter here
  • The agency also published the latest raft of Special Permit (SP) actions.  As usual, many of them concern cylinders, lithium batteries, and authorizations to transport otherwise restricted materials aboard cargo aircraft under unique circumstances.  However, one unusual inclusion is a set related to the FRA’s PTC effort for train control as it relates to the carriage of hazardous materials.  See the full set of activity here:


  • The agency published an ICR in relation to its ongoing commitment to administer state level environmental programs.  States programs must meet certain strict EPA guidelines in order to remain certified. See the ICR here
  • EPA also announced it is accepting nominations for its “Electronic Hazardous Waste Manifest Advisory Board” which will assist it with policy decisions regarding this new way to report hazardous waste transport.  Stakeholders are invited to submit nominees via the portal beginning here


The agency renewed an ICR related to its collection of data on the use of inorganic arsenic in industry.  A hazardous substance, arsenic is closely monitored by the agency. See the ICR here


The agency has issued a proposed revision to its quarterly process for collecting information about the effort by railroads to install Positive Train Control (PTC) equipment aboard trains.  The “PTC Mandate” deadline is this December 31st, so the effort is in high gear.  FRA states that the revisions under consideration will make reporting on vital metrics easier and the data more easily understandable by stakeholders. See the proposal here

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