REGULATIONS
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The last of the modal presentations came
from John Heneghan, director of PHMSA’s southern region office. Penalties will always be a tool in the box, he said, but added: “My job is not to catch you doing wrong but to encourage you to do it right.” That typified his approach: the need for cooperation between PHMSA, the regulated industry and other stakeholders. The field operations offices are the “eyes
and ears” of PHMSA, Heneghan said, during an impassioned presentation that revisited the ValuJet incident in all its horrific detail to press home his exhortation to do things right. Field operations personnel have to have expertise in a wide variety of topics – at the moment the most important of those include gas cylinders (especially non- domestic cylinders), fireworks, hoverboards (and other lithium battery-powered products), and Ebola and other select agents. In addition, there are incident response and accident investigation duties, outreach efforts and workshops, and multi-agency strike force operations. Heneghan gave as an example of the “eyes
and ears” role the issue of friction-fit cans, used primarily to contain paints, varnishes and other similar products. One DOT-approved testing laboratory has reported that it is having a hard time getting these cans to pass the appropriate UN tests. Should PHMSA be looking at the suitability of cans to ship high vapour products by air? If an aircraft came
down because of this issue, would PHMSA be liable for having been in possession of relevant information and for not acting? Heneghan appealed for help from industry in determining whether this is an actual safety issue and what action, if any, needs to be taken. As a final point, Heneghan sought to
reassure package manufacturers that, during inspections, they will never be asked for pricing information and can redact details of customers on any documentation provided to PHMSA inspectors.
OVER THE COUNTER Also on the agenda at the 2016 COSTHA annual forum was Mary Collins of the US Postal Service (USPS). She explained that restricted goods and articles in the post include not only the nine hazmat classes but also items that are restricted by statute – firearms, medication, intoxicating liquor and goods that emit obnoxious orders – as well as perishable goods. As such, changes to the regulations covering both domestic and international mail go through a lengthier process compared to those applicable to hazardous materials. The International Civil Aviation Organisation
(ICAO) requires each member nation’s postal service to establish procedures when introducing dangerous goods into the air transport chain. Mary noted that USPS works on the basis that any and all mail will go by passenger aircraft. For international mail
some dangerous goods are acceptable in certain quantities – UN 3373 infectious substances, patient specimens and small number of cells or batteries installed in equipment, for example. There is a slightly more relaxed limitation on batteries in domestic transport. USPS therefore has a big job to train all its acceptance personnel to interrogate every parcel offered at its counters. It has another job to police the process and has civil enforcement authority.
The COSTHA agenda also included a number of special interest workshops and round table sessions, covering lithium batteries, packaging issues, the automotive sector, life sciences, deepsea container shipping and operations to and from Mexico. COSTHA has established a working group
that has met the authorities in Mexico and established a channel of communication to help its members with any regulatory queries. It has also identified a commercial source for translations of Mexico’s NOM regulations. In addition, the Council has helped form a coalition of US and Mexican trade associations with the aim of encouraging Mexico’s Secretariat of Communications and Transportation (SCT) to participate in international regulatory meetings and work to align national regulations with the UN model regulations. A further meeting of this coalition was scheduled to take place in April 2016. Another COSTHA working group is aiming
to develop a similar conversation with the authorities in China. This will involve a delegation of interested members taking part in the US/China transport forums. Among its priorities will be the adoption of limited and excepted quantity provisions in the Chinese regulations and easier access to domestic and international regulations applicable in China for all modes. A lot of that work will be progressed
during 2016 so it will be interesting to attend COSTHA’s 2017 annual forum, which will take place in Scottsdale, Arizona beginning on 30 April, to hear about what the Council’s efforts have achieved. Full information on that event can be found on COSTHA’s website,
www.costha.com. HCB
WWW.HCBLIVE.COM
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