Our February Newsletter version of getting
on a soapbox and suggesting that the DOT's Research and Special
Programs Administration (RSPA) ought to re-visit training requirements
was unnecessary. Indeed, RSPA obviously was working very hard for
many, many months putting together an Advance Notice of Proposed
Rulemaking (ANPRM). The Docket Number is RSPA-02-11654 (HM-228)
and it was published in the U.S. Federal Register/Vol. 67, No. 38/Tuesday,
February 26, 2002.
It deals with a large number of issues relating to hazardous materials/dangerous
goods shipments by air and special initiatives that are required
for domestic, export, and import shipments.
HM-228 contains a significantly more issues than we listed in our
Newsletter. It is a very thoughtful review of present regulations,
misconceptions, and proposed revisions. You can download a copy
by clicking on the following link: http://hazmat.dot.gov/2002_11654.pdf
If you wish to comment to RSPA about the proposed rulemaking you
must do so by May 31, 2002 - the end of this month.
If you are involved U.S. shipments by air this should be mandatory
reading and if you have any thoughts on the subject you can and
should comment. You can comment by formal letter (2 copies) [see
addresses on page 8769] or electronically at: http://dms.dot.gov
In both cases (snail mail or e-mail) refer to the Docket Number
RSPA-02-11654 (HM-228) [RIN 2137-AD18]. If you are interested in
reading comments that have been submitted you may use the following
When the docket search comes up, scroll down to Item 14, then click
on "Public Comments", then scroll down and click on RIN,
then insert 2137-AD18 (the RIN Number). See, we try to make
things easy for you.
Major issues include, but are not limited to:
- Undeclared dangerous goods
- How can carriers and the government detect these shipments
- Display of signs at passenger and cargo terminals
- Responsibilities of packaging, shipping, and freight forwarding
- ICAO Technical Instructions - DOT/RSPA makes no mention of
- Shipper's obligations for training under 14CFR - presumably
a 1 year recurrent cycle
- A variety of revisions to 49CFR parts 171, 172, 173, and 175
- Reporting discrepancies
- Airline Comat shipments
- And many more issues or questions by RSPA - about 50 or more.
We would point of that of the comments submitted to RSPA so far,
the first one is from a private individual who is concerned for
safety in air transport. Her comments and suggestions are noteworthy.
Note that you do not have to be a corporation or trade group in
order to comment. Please remember that the cut-off date is by May
Security in Transportation
On 2 May, RSPA also announced proposed new security initiatives
and training requirements that will affect the handling of hazardous
materials. They are covered by Docket Number RSPA-02-12064 (HM-232).
As proposed this rule would provide new requirements for copies
of registration certificates to be placed in vehicles carrying dangerous
goods, new paperwork requirements, formal security plans, and mandatory
security training for hazmat employees. RSPA estimates that the
additional training ought to be one hour.
The link is:
In view of 9-11 we urge you to check out this proposed rule as
well. Non-U.S. shippers and carriers should examine the proposed
rule and feel free to comment. If you wish to comment follow the
same procedure as above. For this NPRM the RIN number is: 2137-AD66
The cut-off date for comments is 3 June 2002. Comments can also
be submitted electronically.
R-A Specialists' Website:
In our Newsletter for December
2001 we did a walk-through over our entire website.
We did receive a number of compliments about that attempt
to get visitors more involved in HAZMAT safety. We are
presently working on improving the walk-through with
both visual and verbal prompts. We hope you will find
it helpful. It should be up and running by next month.
You will have the option to use it visually, or with
a visual and audio version, or not at all.
We added a new link last month. Hazmat
Packager and Shipper, the premier trade magazine
dealing with all dangerous goods issues was added to
our links (top right hand corner of our welcome page).
The magazine's outstanding contributors alert us to
new issues constantly and clarify regulations with each
issue. Check it out.
If you are deeply involved with dangerous goods regulations
and compliance you will have a lot of reading, thoughtful
consideration, and possibly writing to do this month.
We will not challenge you with a quiz this month. But
we will resume the feature with our next newsletter.