DG Digest: PHMSA Issues Safey Advisory for DOT-39 Cylinders and IATA Issues Revised 2017 Guidance for Lithium Batteries

The TSA issued a new and far more stringent proposal for security training that may impact freight and passenger railroad operations as well as mass transit and long-distance bus services. Meanwhile, it’s “Season’s Greetings” as Canadian National Railway’s Illinois Central subsidiary visits Melvin, Illinois with its annual Holiday Special. Image © 12/2013 by Nikki Burgess; all rights reserved.

It’s the countdown-to-the-holiday week!  However you may or may not choose to celebrate the coming holiday period, I know that I speak for the entire Labelmaster family in expressing the hope that you are able to do so in peace, and surrounded by your friends and loved ones.  We also thank you so very much for your choice to make our solutions part of how you accomplish your goals.  We appreciate the opportunity!  Let’s take a look at what happened over the last week in the world of regulations:

FAA

The agency announced the 27th RTCA SC–225 Rechargeable Lithium Batteries and Battery Systems Plenary.  The meeting will be held February 07, 2017 09:00 a.m.–05:00 p.m.  Here’s all the details if you’d like to contribute

PHMSA

The agency is issuing a safety advisory notice to inform offerors and users of DOT Specification 39 (DOT–39) cylinders that DOT–39 cylinders with an internal volume exceeding 75 cubic inches (in3) (1.23 L) should not be filled with liquefied flammable compressed gas. PHMSA maintains filling or transporting DOT–39 cylinders with an internal volume exceeding 75 in3 (1.23 L) is not safe. See the notice here

Transport Canada

Transport Canada is conducting a consultation (i.e. public comment period) on proposed amendments to the Transportation of Dangerous Goods Regulations (TDGR).   The proposals this time are extensive and range from the addition of many new and revised definitions of terms, through new ways to deal with regulatory exemptions,  issues surrounding classification, labeling and document requirements, packaging revisions, and a variety of miscellaneous issues like inspections and petroleum markings.  Training is also addressed.  If you would like a copy of the full set of the proposals, Transport Canada offers an email portal with which to request them.  Here it is

Lithium Batteries by Air

In what is becoming an annual New Year’s event, the International Air Transport Association (IATA) published revised guidance outlining the many changes that will impact the shipment of Lithium Batteries by air—this time covering 2017.  As the premier private safety of flight organization in the world, a large majority of global air transport operations are conducted under IATA’s rules structure.  See the guidance here

EPA

In an action which may subject small manufacturers to more stringent standards under the revised Toxic Substances Control Act (TSCA), the EPA is revising downwards the income and activity levels deemed relevant to inclusion under the standard.  You may be potentially affected by this action if you manufacture or process chemical substances or mixtures. Potentially affected entities may include:

  • Basic Chemical Manufacturers (NAICS code 3251)
  • Resin, Synthetic Rubber, and Synthetic Fibers/Filament Manufacturers (NAICS code 3252)
  • Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturers (NAICS code 3255)
  • Paint, Coating, and Adhesive Manufacturers (NAICS code 3255)
  • Other Chemical Product and Preparation Manufacturers (NAICS code 3259)
  • Petroleum Refineries (NAICS code 32411).

See the notice’s details for further information

TSA

The agency is proposing to require security training for employees of freight railroad carriers, public transportation agency rail mass transit and bus systems, passenger railroad carriers, and over-the-road bus (OTRB) companies. Owner/operators of would be required to train employees performing security-sensitive functions using a curriculum addressing preparedness and how to observe, assess, and respond to terrorist related threats and/or incidents. TSA also seeks to expand its current requirements for rail security coordinators and the reporting of significant security concerns currently limited to railroads and the rail operations of public transportation systems to include the bus components of public transportation systems and OTRB companies.  If instituted as proposed the regulations represent a major and at least potentially costly expansion of TSA authority into the nation’s transport security infrastructure for ground based modes.  See the proposal here

OSHA

OSHA is amending its recordkeeping regulations to clarify that the duty to make and maintain accurate records of work-related injuries and illnesses to employees is an ongoing obligation. The duty to record an injury or illness continues for as long as the employer must keep records of the recordable injury or illness; the duty does not expire just because the employer fails to create the necessary records when first required to do so. This final rule becomes effective on January 18, 2017.  See it here


Labelmaster is a full service provider of products and services for the Hazardous Materials and Dangerous Goods professional, shippers, transport operators, and EH&S providers. See our full line of solutions at www.labelmaster.com.

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