by Steve Schulte, CHMM, CPP, Fellow
The Pipeline and Hazardous Materials Safety Administration (PHMSA) of the U.S. Department of Transportation have provided an update on the progress of HM-215O to the Dangerous Goods Advisory Council (DGAC) at their Annual Summit held in Crystal City, Virginia on October 22-24, 2018.
What is HM-215O?
The HM-215O rulemaking was issued to maintain alignment with the international regulations on the transport of hazardous materials/dangerous goods. It would harmonize the U.S. Hazardous Materials Transport regulations with the international Dangerous Goods Transport regulations, by adopting applicable parts of the 20th Revised edition of the UN Recommendations on the Transport of Dangerous Goods (UNRTDG).
When will HM-215O be issued?
The issuance of HM-215O is anticipated to be later than previous HM-215 rulemakings due to the new Administration’s policy and guidelines to reduce regulatory burdens on industry. Typically, the issuance of HM-215 is normally in January, with a voluntary compliance date immediately and mandatory compliance date one year later.
HM-215O is currently under Department review and may not be issued prior to January 2019. In anticipation of this delay, PHMSA has prepared and anticipates issuing anti-enforcement notices. Anti-enforcement notices will allow industry to continue to offer transportation of their dangerous goods in compliance with existing regulations, and not be penalized for not following the new regulations.
It should be noted that the delay of the issuing HM-215O may create delays and frustrated shipments of dangerous goods. This is because the U.S. Hazardous Materials regulations may not be harmonized with the dangerous goods regulations for shipment via Air, Vessel and Surface shipments outside the U.S. As a result, proactive contact by industry with their carriers and freight forwarders is recommended.
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HM-215O, PHMSA, Dangerous Goods, HazMat, DOT, Pipeline and Hazardous Materials Safety Administration, of the U.S. Department of Transportation, Dangerous Goods Advisory Council, DGAC