News & Analysis as of

Department of Transportation (DOT) PHMSA Hazardous Substances

Benesch

Hazmat Modernization Comment Period Approaching

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The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (“PHMSA”) is accepting comments through December 4, 2023 regarding forty-six (46) topics for proposed updates to the Hazardous...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an August 28th letter the application of the Hazardous Materials Regulations (“HMR”) applicable to the maintenance of Department of...more

K&L Gates LLP

LNG by Rail Rule Suspension

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The US Department of Transportation (USDOT) is suspending a rule that allows liquefied natural gas (LNG) to be transported by rail in specialized tank cars, starting 31 October 2023. This final rule overturns a Trump-era rule...more

Bergeson & Campbell, P.C.

PHMSA Requests Feedback on Recycled Plastics Policy

On April 14, 2023, the Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) published a request for feedback on its recycled plastics policy. 88 Fed. Reg. 23140. PHMSA states...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Materials Regulations Proposed Rulemaking: Pipeline and Hazardous Materials Safety Administration Adoption of...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a Notice of Proposed Rulemaking (“NPRM”) that includes amendments to the federal Hazardous Materials Regulations (“HMR”). See...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a December 22, 2022, interpretive letter clarification of Hazardous Materials Regulations (“HMR”) as to what constitutes a “contiguous facility...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The United States Department of Transportation Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a December 6th interpretive letter the application of the Hazardous Materials Regulations (“HMR”) to...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The United States Department of Transportation Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an October 13th letter the application of the Hazardous Materials Regulations (“HMR”) to a...more

Bergeson & Campbell, P.C.

PHMSA Publishes First Set of FAQs Specific to HMR Applicability, Will Address Incident Reporting Requirements Next

On December 9, 2022, the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice responding to comments received on its initiative to convert historical...more

Bergeson & Campbell, P.C.

PHMSA Seeks Comment on Initiative to Convert Historical LOIs into HMR FAQs

The U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) announced on March 22, 2022, an initiative to convert historical letters of interpretation (LOI) applicable to the...more

Cozen O'Connor

Louisiana AG Leads Coalition Protesting LNG Transportation Regulation

Cozen O'Connor on

A 25-state coalition of AGs, led by Louisiana AG Jeff Landry, has written a letter to Tristan Brown, Acting Administrator of the U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration,...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Roadway Striping/Use of Non-DOT Specification Cargo Tanks: Pipeline and Hazardous Materials Safety Administration Issues Safety...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued an August 12th Safety Advisory Notice titled: Roadway Striping and Use of Non-DOT Specification Cargo Tanks (“Safety Notice”) PHMSA states...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials Regulations: Pipeline and Hazardous Materials Safety Administration Interpretive Letter...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a May 19th letter the applicability of the Hazardous Materials Regulations (“HMR”) to the transportation of internal combustion...more

Mitchell, Williams, Selig, Gates & Woodyard,...

State of Washington Rail Transport Crude Oil Volatility Rules: U.S. Pipeline and Hazardous Materials Safety Administration Issues...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) announced on May 11th, its determination that the Federal Hazardous Materials Transportation Act (“HMTA”) preempts the State of Washington’s...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: U.S. Pipeline and Hazardous Materials Safety Administration Addresses Question Regarding...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 31st letter the application of the Hazardous Materials Regulations (“HMR”) applicable to shipping papers. PHMSA was...more

Hogan Lovells

DOT and PHMSA issue new enforcement policy regarding recurrent training requirements in response to COVID-19

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On 25 March 2020 the U.S. Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) published a new enforcement policy regarding recurrent training requirements for hazardous...more

King & Spalding

PHMSA Issues Final Rule on Underground Natural Gas Storage Safety Establishing a Phased-in, Multi-Year Timeframe for Integrity...

King & Spalding on

On February 12, 2020, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued its long-awaited Final Rule establishing safety regulations applicable to underground...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Medical...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 2nd interpretive letter a question regarding the application of the Hazardous Materials Regulations (“HMR”) to...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Addresses Question Involving MC 300...

The United States Department of Transportation Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a November 26th letter a question addressing the Hazardous Materials Regulations (“HMR”) pressure...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transporting Skid Tanks: Mark Morgan (PMAA Weekly Review) Addresses Hazardous Materials Regulations Issues

Mark S. Morgan authored an article in the December 13th Petroleum Marketers Association of America (“PMAA”) publication, PMAA Weekly Review titled: U.S. DOT hazardous Material Requirements for Transporting “Empty” Skid...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an October 15th interpretive letter clarification of the Hazardous Material Regulation (“HMR”) pertaining to the classification of explosives. ...more

Hogan Lovells

PHMSA proposes new rule authorizing the transport of LNG by rail

Hogan Lovells on

The U.S. Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice of proposed rulemaking (NPRM) to authorize the transport of liquefied natural gas (LNG) by...more

Holland & Knight LLP

PHMSA Issues NPRM for LNG by Rail

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On October 24, 2019, The U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) published a Notice of Proposed Rulemaking (NPRM) in the Federal Register following its earlier...more

Benesch

Hazardous Materials Regulations Compliance: Jail Time May Be Waiting

Benesch on

The transportation of hazardous materials (hazmat) is an subject that holds significant safety implications for carriers, shippers, intermediaries and the general public. Compliance programs and their requirements vary widely...more

Mitchell, Williams, Selig, Gates & Woodyard,...

State of Washington Rail Transport Crude Oil Volatility Rules: U.S. Pipeline and Hazardous Materials Safety Administration Public...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a July 24th Public Notice and Invitation to Comment (“Notice”) addressing the states of North Dakota and Montana’s (“States”) request...more

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