May 25, 2012: (NPRM) PHMSA – LTD QTY & ORM-D markings

HM-215K

PHMSA published an NPRM (Notice of Proposed Rulemaking) to address appeals to HM-215K International Harmonization Rules (1/1/2011 – 12/31/2011). Among other items, PHMSA proposed extending the ORM-D transition period by two years. The ORM-D (Consumer Commodity) hazard class is supposed to be phased out in stages through1/1/2013 for air or 1/1/2014 for rail, highway, and vessel when it will be dissolved completely. However, due to comments from the regulated community, PHMSA has now proposed to extend only the rail, highway, and vessel phase-out period of ORM-D until 1/1/2015.

Also, when the final rule is issued, the old limited quantity marking of the square-on-point with UN Number will be permitted until 12/31/2012 for air and 12/31/2013 for rail, highway, and vessel. After that the new black and white mark with a Y will be required for air (1/1/2013) and the blank black and white mark will be required for rail, highway, and vessel (1/1/2014). See below.

  •  The old Square-on-Point LTD QTY marking will be permitted until 12/31/2012 (AIR) and 12/31/2013 (RAIL, HIGHWAY, VESSEL)
  • The Y LTD QTY Marking be required for air transport of LTD QTY 1/1/2013.
  • The Blank LTD QTY Marking will be required for rail, highway, or vessel transport of LTD QTY 1/1/2014.

Wht Sq on Pt       Y LTD QTY       Blank LTD QTY

Author: Wendy Buckley

Wendy has been in the hazardous materials industry for over 17 years. She worked for both the Federal Railroad Administration and New Jersey State Department of Transportation as a Railroad Hazardous Materials Safety Inspector. Wendy was an Investigator with the Office of Inspector General at Amtrak, a Multi-Modal HazMat Instructor and Auditor with a premier training and consulting company, and managed the Regulatory Affairs department at a multi-billion dollar, multi-national laboratory supply company. Wendy started her career as a Hazardous Materials Technician and Firefighter and today she is the President & Founder of Specialty Transportation and Regulatory Services, a hazardous materials and hazardous waste management consulting firm. Wendy has multiple degrees from several private and public Universities.