Welcome to July. The week just ended brought an enormous set of regulatory changes and proposals, in sharp contrast to the rather limited activity that has previously characterized the last several months. Several agencies relevant to HSE and DG stakeholders were affected, so fill your coffee cup and let’s dive right in:
PHMSA
The agency took numerous actions this week:
Proposed rules
Perhaps the most widely impactful action to DG stakeholders is a proposed rule that will allow for reduced sized (at least 25mm) Limited Quantity markings on domestic ground packages, regardless of package size. That’s a big change. The same proposal notes that full sized marks must still be used on the exterior of overpacks when applicable. Note again, this is ONLY for US ground service. See this action here:
Another impactful action: This NPRM proposes to revise the Hazardous Materials Regulations (HMR) to allow for the continued use of packagings authorized under a manufacturing special permit for duration of the useful life of the package. The current HMR provisions require an otherwise safe and usable package to be discontinued solely because the original special permit has expired or was not renewed.
The Materials of Trade exception in US 49 CFR 173.6 would be modified to allow for the carriage of much larger quantities of lithium batteries under this NRPM:
49 CFR 172.101 Appendix A, the Hazardous Substance List, would be removed from the HMR under this proposal. Users would have to instead consult the corresponding list in the US 40 CFR Hazardous Waste Regulations.
This proposal would alter the definition of aerosols under the HMR to more align it with international standards. It would for example permit the classification of some pure gases as aerosols if they meet the container definition. See this NPRM:
There is a proposal to streamline SP renewal requirements and processes affecting certain flammable liquids used as fuels:
Another NPRM would allow for renewal requests for Special Permits prior to the current 60-day window:
Hazardous Materials Registration would be by electronic payment only, elimination paper options, under this NPRM:
Other NPRM actions contain what might be described as more industry specific impacts:
Fireworks certifications – 2025-12082.pdf
Security training for farms using DG – 2025-12095.pdf
A set of NPRMs would affect and reduce recordkeeping requirements in some circumstances:
Domestic carriers – 2025-12096.pdf
Rail reporting requirements: 2025-12098.pdf
SP changes and Incorporations
A variety of proposed changes will incorporate various special permits (SP) into the HMR. This would have the effect of elimination the need for those SP’s to be renewed and pass their allowance to the stakeholder population in general.
This action would incorporate SP21478 into the HMR. This would allow for what amounts to the unregulated transport of most empty (save for residues) IBC’s. That’s quite a change. See this action here:
Here are other proposed SP incorporations to the HMR:
SP14175 re cylinder testing – 2025-12083.pdf
SP21287 re transport of small refrigerating machines containing DG – 2025-12121.pdf
SP21379 re transport of large refrigerating machines containing DG – 2025-12100.pdf
There was also a final rule correction made to the recent LNG by rail rule, affecting weld and plate thickness requirements. See the correction here:
FRA
The agency made administrative changes via direct final rule to its Drug & Alcohol Control Regulations. The agency contends that these changes make no substantive modification to the existing requirements. See the rule here:
The agency also proposed numerous amendments to the technical side of its regulatory regime that govern the use and control of equipment, recordkeeping, and risk control and reduction. Interested carrier and operator stakeholders can access these varied changes in the link below to the July 1, 2025 FR:
https://www.federalregister.gov/documents/current
OSHA
The agency is proposing a varied and comprehensive set of changes in its respiratory protection standard, specifically those portions affecting respirators and their requirements for filtering various types of chemicals and contaminants. See the specific standards and the changes proposed for numerous various chemicals at the several links below:
2025-11629.pdf 2025-11630.pdf 2025-11631.pdf 2025-11632.pdf 2025-12235.pdf
2025-11633.pdf 2025-11634.pdf 2025-11635.pdf 2025-11637.pdf 2025-11638.pdf
2025-11639.pdf 2025-11640.pdf 2025-11641.pdf 2025-11642.pdf 2025-11643.pdf
The agency is proposing to rescind its reporting requirements for tracking COVID-19 infection vectors in Healthcare settings. See the proposed recission here:
OSHA proposes to clarify its interpretation of the General Duty Clause, 29 U.S.C. 654(a)(1), to exclude from enforcement known hazards that are inherent and inseparable from the core nature of a professional activity or performance. See further information here:
Labelmaster is a full-service provider of products, shipping and training software, and professional consulting services to assist the DG and HS&E professional to comply with national and international regulations. See our full line of solutions at www.labelmaster.com.
