By Prokopis A. Christou, PE
In today's issue, we will focus on recent activities by the Research and Special Programs Administration (RSPA) as published in the Federal Register.
Some explanations: RSPA is an agency of the U.S. Department of Transportation (DOT). It is the Federal agency charge to the hazardous materials regulatory program in the U.S. For modal requirements (air, water and highway), RSPA works together with he modal transportation agencies: Federal Air Administration , U.S. Coast Guard, Federal Motor Carrier Safety Administration. The term hazardous materials used in the U.S. is identical to the term dangerous goods used internationally. The Federal Register is the "newspaper" of U.S. government where all Federal agencies must publish notices of regulatory actions.
As a result of the terrorist attacks on the World Trade Center and the Pentagon on September 11, 2001, and subsequent threats related to biological materials, government agencies, industry trade associations issued advisories and guidance documents for enhancing security of hazardous materials produced, stored or transported in the United States.
In a notice published in the February 14, 2001 Federal Register, RSPA advises shippers and carriers of voluntary measures to enhance the security of hazardous materials shipments during transportation. The notice addresses personnel, facility, and en route security issues and includes contact points for obtaining additional, more detailed information. To assist in performing appropriate risk assessments, RSPA posted a Risk Management Self-Evaluation Framework on its website http://hazmat.dot.gov .
This advisory notice does not impose any mandatory requirements. The voluntary measures described in the notice are due diligence measures that can enhance facility security and shipment security. Most of the suggestions about security plans, personnel security, and facility security are generic enough and applicable to all types and organizations. They are worth considering for office buildings as well.
Many organizations and trade association have also issued guidance documents for security and risk management issues. You may want to identify groups that are relevant to your organization's operations and review guidance documents they have issued. You can find a list of these groups including telephone numbers and web sites in the DOT advisory notice
Related documents available on the Hazmat 101 Web (Listed under Files)
RSPA is considering changes to the requirements in the Hazardous Materials Regulations (HMR) on the transportation of hazardous materials by aircraft. These changes would modify or clarify requirements to promote safer transportation practices; promote compliance and enforcement; eliminate unnecessary regulatory requirements; convert certain exemptions into regulations of general applicability; finalize outstanding petitions for rulemaking; facilitate international commerce; and make these requirements easier to understand. In addition, RSPA is denying a petition for rulemaking in this document.
If you are routinely involved in shipments by air, even if the shipment will travel by air part of its trip, you may want to review the specific details of the advance proposal. If you use IATA or ICAO to prepare your shipments, you are shipping by air. RSPA accepts written comments until May 31, 2002. More information: See the February 26, 2002 Federal Register
RSPA proposes to amend the Hazardous Materials Regulations to permit, for an interim period and subject to certain unloading conditions, the unloading of intermodal (IM) portable tanks transporting certain liquid hazardous materials that are not equipped with a thermal means of remote activation of the internal self-closing stop-valves fitted on the bottom discharge outlets. Permitting such unloading for an interim period would afford operators time to bring the IM portable tanks into conformance with the regulations. RSPA accepts written comments until April 8, 2002. For more information, see the February 22, 2002 Federal Register
About the Author
Prokopis Christou, P.E. has 14 years of diverse experience in managerial,
technical, and teaching responsibilities in environmental, safety,
transportation, regulatory, and engineering matters. Email: prokopis@hotmail.com