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PHMSA is amending the Hazardous Materials Regulations (HMR) to maintain alignment with international regulations and standards by adopting various amendments, including changes to proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, air transport quantity limitations, and vessel stowage requirements. PHMSA is also withdrawing the unpublished November 28, 2022, Notice of Enforcement Policy Regarding International Standards on the use of select updated international standards in complying with the HMR during the pendency of this rulemaking.

DATES:

Effective date: This rule is effective May 10, 2024.

Voluntary compliance date: January 1, 2023.

Delayed compliance date: April 10, 2025.

This final rule is published in the Federal Register April 10, 2024.

View final rule.

§171.7 Reference material.
(t)(1), (v)(2), and (w)(32) through (81) Revised View text
(w)(82) through (92) Added View text
(aa)(3) and (dd)(1) through (4) Revised View text
§171.12 North American shipments.
(a)(4)(iii) Revised View text
§171.23 Requirements for specific materials and packagings transported under the ICAO technical instructions, IMDG code, Transport Canada TDG regulations, or the IAEA regulations.
(a)(3) Revised View text
§171.25 Additional requirements for the use of the IMDG code.
(c)(3) and (4) Revised View text
(c)(5) Added View text
§172.101 Purpose and use of the hazardous materials table.
Section heading Revised View text
(c)(12)(ii) Revised View text
Hazardous materials table, multiple entries Revised, added, removed View text
§172.102 Special provisions.
(c)(1) special provisions 78, 156, and 387 Revised View text
(c)(1) special provisions 396 and 398 Added View text
(c)(1) special provision 421 Removed and reserved View text
(c)(2) special provision A54 Revised View text
(c)(2) special provisions A224 and A225 Added View text
(c)(4) Table 2—IP Codes, special provision IP15 Revised View text
(c)(4) Table 2—IP Codes, special provision IP22 Added View text
§173.4b De minimis exceptions.
(b)(1) Revised View text
§173.21 Forbidden materials and packages.
(f) introductory text, (f)(1), and (f)(2) Revised View text
§173.27 General requirements for transportation by aircraft.
(f)(2)(i)(D) Revised View text
§173.124 Class 4, Divisions 4.1, 4.2 and 4.3— Definitions.
(a)(4)(iv) Removed View text
§173.137 Class 8—Assignment of packing group.
Introductory text Revised View text
§173.151 Exceptions for Class 4.
(d) introductory text Revised View text
§173.167 ID8000 consumer commodities.
Entire section Revised View text
§173.185 Lithium cells and batteries.
(a)(3) introductory text and (a)(3)(x) Revised View text
(a)(5) Added View text
(b)(3)(iii)(A) and (B) Revised View text
(b)(3)(iii)(C) Added View text
(b)(4)(ii) and (iii) Revised View text
(b)(4)(iv) Added View text
(b)(5), (c)(3) through (5), and (e)(5) through (7) Revised View text
§173.224 Packaging and control and emergency temperatures for self-reactive materials.
(b)(4) Revised View text
Table following (b)(7) Revised View text
§173.225 Packaging requirements and other provisions for organic peroxides.
Table 1 to paragraph (c) Revised View text
Table following paragraph (d) Retitled View text
Table following paragraph (g) Revised View text
§173.232 Articles containing hazardous materials, n.o.s.
(h) Added View text
§173.301b Additional general requirements for shipment of UN pressure receptacles.
(c)(1), (c)(2)(ii) through (iv), (d)(1), and (f) Revised View text
§173.302b Additional requirements for shipment of non-liquefied (permanent) compressed gases in UN pressure receptacles.
(g) Added View text
§173.302c Additional requirements for the shipment of adsorbed gases in UN pressure receptacles.
(k) Revised View text
§173.311 Metal Hydride Storage Systems.
Entire section Revised View text
§175.1 Purpose, scope, and applicability.
(e) Added View text
§175.10 Exceptions for passengers, crewmembers, and air operators.
(a) introductory text, (a)(14) introductory text, (a)(15)(v)(A), (a)(15)(vi)(A), (a)(17)(ii)(C), (a)(18) introductory text, and (a)(26) introductory text Revised View text
§175.33 Shipping paper and information to the pilot-in-command.
(a)(13)(iii) Revised View text
§178.37 Specification 3AA and 3AAX seamless steel cylinders.
(j) Revised View text
§178.71 Specifications for UN pressure receptacles.
(f)(4), (g), (i), (k)(1)(i) and (ii), (m), and (n) Revised View text
§178.75 Specifications for MEGCs.
(d)(3) introductory text and paragraphs (d)(3)(i) through (iii) Revised View text
§178.609 Test requirements for packagings for infectious substances.
(d)(2) Revised View text
§178.706 Standards for rigid plastic IBCs.
(c)(3) Revised View text
§178.707 Standards for composite IBCs.
(c)(3)(iii) Revised View text
§180.207 Requirements for requalification of UN pressure receptacles.
(d)(3) and (5) Revised View text
(d)(8) Added View text

Previous Text

§171.7 Reference material.

* * * * *

(t) * * *

(1) ICAO Doc 9284. Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions), 2021-2022 Edition, copyright 2020; into §§171.8; 171.22 through 171.24; 172.101; 172.202; 172.401; 172.407; 172.512; 172.519; 172.602; 173.56; 173.320; 175.10, 175.33; 178.3.

* * * * *

(v) * * *

(2) International Maritime Dangerous Goods Code (IMDG Code), Incorporating Amendment 40-20 (English Edition), (Volumes 1 and 2), 2020 Edition, copyright 2020; into §§171.22; 171.23; 171.25; 172.101; 172.202; 172.203; 172.401; 172.407; 172.502; 172.519; 172.602; 173.21; 173.56; 176.2; 176.5; 176.11; 176.27; 176.30; 176.83; 176.84; 176.140; 176.720; 176.906; 178.3; 178.274.

(w) * * *

(32) ISO 9809-2:2000(E): Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 2: Quenched and tempered steel cylinders with tensile strength greater than or equal to 1 100 MPa., First edition, June 2000, into §§178.71; 178.75.

(33) ISO 9809-2:2010(E): Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 2: Quenched and tempered steel cylinders with tensile strength greater than or equal to 1100 MPa., Second edition, 2010-04-15, into §§178.71; 178.75.

(34) ISO 9809-3:2000(E): Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders, First edition, December 2000, into §§178.71; 178.75.

(35) ISO 9809-3:2010(E): Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders, Second edition, 2010-04-15, into §§178.71; 178.75.

(36) ISO 9809-4:2014(E), Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 4: Stainless steel cylinders with an Rm value of less than 1 100 MPa, First edition, 2014-07-15, into §§178.71; 178.75.

(37) ISO 9978:1992(E)—Radiation protection—Sealed radioactive sources—Leakage test methods. First Edition, (February 15, 1992), into §173.469.

(38) ISO 10156:2017(E), Gas cylinders—Gases and gas mixtures—Determination of fire potential and oxidizing ability for the selection of cylinder valve outlets, Fourth edition, 2017-07; into §173.115.

(39) ISO 10297:1999(E), Gas cylinders—Refillable gas cylinder valves—Specification and type testing, First Edition, 1995-05-01; into §§173.301b; 178.71.

(40) ISO 10297:2006(E), Transportable gas cylinders—Cylinder valves—Specification and type testing, Second Edition, 2006-01-15; into §§173.301b; 178.71.

(41) ISO 10297:2014(E), Gas cylinders—Cylinder valves—Specification and type testing, Third Edition, 2014-07-15; into §§173.301b; 178.71.

(42) ISO 10297:2014/Amd 1:2017(E), Gas cylinders—Cylinder valves—Specification and type testing—Amendment 1: Pressure drums and tubes, Third Edition, 2017-03; into §§173.301b; 178.71.

(43) ISO 10461:2005(E), Gas cylinders—Seamless aluminum-alloy gas cylinders—Periodic inspection and testing, Second Edition, 2005-02-15 and Amendment 1, 2006-07-15; into §180.207.

(44) ISO 10462:2013(E), Gas cylinders—Acetylene cylinders—Periodic inspection and maintenance, Third edition, 2013-12-15; into §180.207.

(45) ISO 10692-2:2001(E), Gas cylinders—Gas cylinder valve connections for use in the micro-electronics industry—Part 2: Specification and type testing for valve to cylinder connections, First Edition, 2001-08-01; into §§173.40; 173.302c.

(46) ISO 11114-1:2012(E), Gas cylinders—Compatibility of cylinder and valve materials with gas contents—Part 1: Metallic materials, Second edition, 2012-03-15; into §§172.102; 173.301b; 178.71.

(47) ISO 11114-1:2012/Amd 1:2017(E), Gas cylinders—Compatibility of cylinder and valve materials with gas contents—Part 1: Metallic materials—Amendment 1, Second Edition, 2017-01; into §§172.102; 173.301b; 178.71.

(48) ISO 11114-2:2013(E), Gas cylinders—Compatibility of cylinder and valve materials with gas contents—Part 2: Non-metallic materials, Second edition, 2013-04; into §§173.301b; 178.71.

(49) ISO 11117:1998(E): Gas cylinders—Valve protection caps and valve guards for industrial and medical gas cylinders—Design, construction and tests, First edition, 1998-08-01; into §173.301b.

(50) ISO 11117:2008(E): Gas cylinders—Valve protection caps and valve guards—Design, construction and tests, Second edition, 2008-09-01; into §173.301b.

(51) ISO 11117:2008/Cor.1:2009(E): Gas cylinders—Valve protection caps and valve guards—Design, construction and tests, Technical Corrigendum 1, 2009-05-01; into §173.301b.

(52) ISO 11118(E), Gas cylinders—Non-refillable metallic gas cylinders—Specification and test methods, First edition, October 1999; into §178.71.

(53) ISO 11118:2015(E), Gas cylinders—Non-refillable metallic gas cylinders—Specification and test methods, Second edition, 2015-09-15; into §§173.301b; 178.71.

(54) ISO 11119-1(E), Gas cylinders—Gas cylinders of composite construction—Specification and test methods—Part 1: Hoop-wrapped composite gas cylinders, First edition, May 2002; into §178.71.

(55) ISO 11119-1:2012(E), Gas cylinders—Refillable composite gas cylinders and tubes—Design, construction and testing—Part 1: Hoop wrapped fibre reinforced composite gas cylinders and tubes up to 450 l, Second edition, 2012-08-01; into §§178.71; 178.75.

(56) ISO 11119-2(E), Gas cylinders—Gas cylinders of composite construction—Specification and test methods—Part 2: Fully wrapped fibre reinforced composite gas cylinders with load-sharing metal liners, First edition, May 2002; into §178.71.

(57) ISO 11119-2:2012(E), Gas cylinders—Refillable composite gas cylinders and tubes—Design, construction and testing—Part 2: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 l with load-sharing metal liners, Second edition, 2012-07-15; into §§178.71; 178.75.

(58) ISO 11119-2:2012/Amd.1:2014(E), Gas cylinders—Refillable composite gas cylinders and tubes—Design, construction and testing—Part 2: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 l with load-sharing metal liners, Amendment 1, 2014-08-15; into §§178.71; 178.75.

(59) ISO 11119-3(E), Gas cylinders of composite construction—Specification and test methods—Part 3: Fully wrapped fibre reinforced composite gas cylinders with non-load-sharing metallic or non-metallic liners, First edition, September 2002; into §178.71.

(60) ISO 11119-3:2013(E), Gas cylinders—Refillable composite gas cylinders and tubes—Design, construction and testing—Part 3: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 l with non-load-sharing metallic or non-metallic liners, Second edition, 2013-04-15; into §§178.71; 178.75.

(61) ISO 11119-4:2016(E), Gas cylinders—Refillable composite gas cylinders—Design, construction and testing—Part 4: Fully wrapped fibre reinforced composite gas cylinders up to 150 L with load-sharing welded metallic liners, First Edition, 2016-02-15; into §§178.71; 178.75.

(62) ISO 11120(E), Gas cylinders—Refillable seamless steel tubes of water capacity between 150 l and 3000 l—Design, construction and testing, First edition, 1999-03; into §§178.71; 178.75.

(63) ISO 11120:2015(E), Gas cylinders—Refillable seamless steel tubes of water capacity between 150 l and 3000 l—Design, construction and testing, Second Edition, 2015-02-01; into §§178.71; 178.75.

(64) ISO 11513:2011(E), Gas cylinders—Refillable welded steel cylinders containing materials for sub-atmospheric gas packaging (excluding acetylene)—Design, construction, testing, use and periodic inspection, First edition, 2011-09-12; into §§173.302c; 178.71; 180.207.

(65) ISO 11621(E), Gas cylinders—Procedures for change of gas service, First edition, April 1997; into §§173.302, 173.336, 173.337.

(66) ISO 11623(E), Transportable gas cylinders—Periodic inspection and testing of composite gas cylinders, First edition, March 2002; into §180.207.

(67) ISO 11623(E):2015, Gas cylinders—Composite construction—Periodic inspection and testing, Second edition, 2015-12-01; into §180.207.

(68) ISO 13340:2001(E), Transportable gas cylinders—Cylinder valves for non-refillable cylinders—Specification and prototype testing, First edition, 2004-04-01; into §§173.301b; 178.71.

(69) ISO 13736:2008(E), Determination of flash point—Abel closed-cup method, Second Edition, 2008-09-15; into §173.120.

(70) ISO 14246:2014(E), Gas cylinders—Cylinder valves—Manufacturing tests and examination, Second Edition, 2014-06-15; into §178.71.

(71) ISO 14246:2014/Amd 1:2017(E), Gas cylinders—Cylinder valves—Manufacturing tests and examinations—Amendment 1, Second Edition, 2017-06; into §178.71.

(72) ISO 16111:2008(E), Transportable gas storage devices—Hydrogen absorbed in reversible metal hydride, First Edition, 2008-11-15; into §§173.301b; 173.311; 178.71.

(73) ISO 16148:2016(E), Gas cylinders—Refillable seamless steel gas cylinders and tubes—Acoustic emission examination (AT) and follow-up ultrasonic examination (UT) for periodic inspection and testing, Second Edition, 2016-04-15; into §180.207.

(74) ISO 17871:2015(E), Gas cylinders—Quick-release cylinder valves—Specification and type testing, First Edition, 2015-08-15; into §173.301b.

(75) ISO 17879: 2017(E), Gas cylinders—Self-closing cylinder valves—Specification and type testing, First Edition, 2017-07; into §§173.301b; 178.71.

(76) ISO 18172-1:2007(E), Gas cylinders—Refillable welded stainless steel cylinders—Part 1: Test pressure 6 MPa and below, First Edition, 2007-03-01; into §178.71.

(77) ISO 20475:2018(E), Gas cylinders—Cylinder bundles—Periodic inspection and testing, First Edition, 2018-02; into §180.207.

(78) ISO 20703:2006(E), Gas cylinders—Refillable welded aluminum-alloy cylinders—Design, construction and testing, First Edition, 2006-05-01; into §178.71.

(79) ISO 21172-1:2015(E), Gas cylinders—Welded steel pressure drums up to 3000 litres capacity for the transport of gases—Design and construction—Part 1: Capacities up to 1000 litres, First edition, 2015-04-01; into §178.71.

(80) ISO 22434:2006(E), Transportable gas cylinders—Inspection and maintenance of cylinder valves, First Edition, 2006-09-01; into §180.207.

(81) ISO/TR 11364:2012(E), Gas cylinders—Compilation of national and international valve stem/gas cylinder neck threads and their identification and marking system, First Edition, 2012-12-01; into §178.71.

* * * * *

(aa) * * *

(3) OECD Guideline for the Testing of Chemicals 431 (Test No. 431): In vitro skin corrosion: reconstructed human epidermis (RHE) test method, adopted 29 July 2016; into §173.137.

* * * * *

(dd) * * *

(1) Recommendations on the Transport of Dangerous Goods, Model Regulations (UN Recommendations), 21st revised edition, copyright 2019; into §§171.8; 171.12; 172.202; 172.401; 172.407; 172.502; 172.519; 173.22; 173.24; 173.24b; 173.40; 173.56; 173.192; 173.302b; 173.304b; 178.75; 178.274; as follows:

(i) Volume I, ST/SG/AC.10.1/21/Rev.21 (Vol. I).

(ii) Volume II, ST/SG/AC.10.1/21/Rev.21 (Vol. II).

(2) Manual of Tests and Criteria (UN Manual of Tests and Criteria), 7th revised edition, ST/SG/AC.10/11/Rev.7, copyright 2019; into §§171.24, 172.102; 173.21; 173.56 through 173.58; 173.60; 173.115; 173.124; 173.125; 173.127; 173.128; 173.137; 173.185; 173.220; 173.221; 173.224; 173.225; 173.232; part 173, appendix H; 175.10; 176.905; 178.274.

(3) Globally Harmonized System of Classification and Labelling of Chemicals (GHS), 8th revised edition, ST/SG/AC.10/30/Rev.8, copyright 2019; into §172.401.

(4) Agreement concerning the International Carriage of Dangerous Goods by Road (ADR), copyright 2020; into §171.8; §171.23 as follows: [Change Notice][Previous Text]

(i) Volume I, ECE/TRANS/300 (Vol. I).

(ii) Volume II, ECE/TRANS/300 (Vol. II).

(iii) Corrigendum, ECE/TRANS/300 (Corr. 1).

* * * * *

§171.12 North American shipments.

* * * * *

(a) * * *

(4) * * *

(iii) Authorized CRC, BTC, CTC or TC specification cylinders that correspond with a DOT specification cylinder are as follows:

TC DOT (some or all of these specifications may instead be marked with the prefix ICC) CTC (some or all of these specifications may instead be marked with the prefix BTC or CRC)
TC-3AM DOT-3A [ICC-3] CTC-3A
TC-3AAM DOT-3AA CTC-3AA
TC-3ANM DOT-3BN CTC-3BN
TC-3EM DOT-3E CTC-3E
TC-3HTM DOT-3HT CTC-3HT
TC-3ALM DOT-3AL
DOT-3B
CTC-3AL
CTC-3B
TC-3AXM DOT-3AX CTC-3AX
TC-3AAXM DOT-3AAX
DOT-3A480X
CTC-3AAX
CTC-3A480X
TC-3TM DOT-3T
TC-4AAM33 DOT-4AA480 CTC-4AA480
TC-4BM DOT-4B CTC-4B
TC-4BM17ET DOT-4B240ET CTC-4B240ET
TC-4BAM DOT-4BA CTC-4BA
TC-4BWM DOT-4BW CTC-4BW
TC-4DM DOT-4D CTC-4D
TC-4DAM DOT-4DA CTC-4DA
TC-4DSM DOT-4DS CTC-4DS
TC-4EM DOT-4E CTC-4E
TC-39M DOT-39 CTC-39
TC-4LM DOT-4L
DOT-8
DOT-8AL
CTC-4L
CTC-8
CTC-8AL

* * * * *

§171.23 Requirements for specific materials and packagings transported under the ICAO technical instructions, IMDG code, Transport Canada TDG regulations, or the IAEA regulations.

(a) * * *

(3) Pi-marked pressure receptacles. Pressure receptacles that are marked with a pi mark in accordance with the European Directive 2010/35/EU (IBR, see §171.7) on transportable pressure equipment (TPED) and that comply with the requirements of Packing Instruction P200 or P208 and 6.2 of the ADR (IBR, see §171.7) concerning pressure relief device use, test period, filling ratios, test pressure, maximum working pressure, and material compatibility for the lading contained or gas being filled, are authorized as follows:

(i) Filled pressure receptacles imported for intermediate storage, transport to point of use, discharge, and export without further filling; and

(ii) Pressure receptacles imported or domestically sourced for the purpose of filling, intermediate storage, and export.

(iii) The bill of lading or other shipping paper must identify the cylinder and include the following certification: “This cylinder (These cylinders) conform(s) to the requirements for pi-marked cylinders found in 171.23(a)(3).”

* * * * *

§171.25 Additional requirements for the use of the IMDG code.

* * * * *

(c) * * *

(3) Except as specified in this subpart, for a material poisonous (toxic) by inhalation, the T Codes specified in Column 13 of the Dangerous Goods List in the IMDG Code may be applied to the transportation of those materials in IM, IMO and DOT Specification 51 portable tanks, when these portable tanks are authorized in accordance with the requirements of this subchapter; and

(4) No person may offer an IM or UN portable tank containing liquid hazardous materials of Class 3, PG I or II, or PG III with a flash point less than 100°F (38°C); Division 5.1, PG I or II; or Division 6.1, PG I or II, for unloading while it remains on a transport vehicle with the motive power unit attached, unless it conforms to the requirements in §177.834(o) of this subchapter.

* * * * *

§172.101 Purpose and use of hazardous materials table.

* * * * *

(c) * * *

(12) * * *

(ii) Generic or n.o.s. descriptions. If an appropriate technical name is not shown in the Table, selection of a proper shipping name shall be made from the generic or n.o.s. descriptions corresponding to the specific hazard class, packing group, hazard zone, or subsidiary hazard, if any, for the material. The name that most appropriately describes the material shall be used; e.g, an alcohol not listed by its technical name in the Table shall be described as “Alcohol, n.o.s.” rather than “Flammable liquid, n.o.s.”. Some mixtures may be more appropriately described according to their application, such as “Coating solution” or “Extracts, flavoring, liquid”, rather than by an n.o.s. entry, such as “Flammable liquid, n.o.s.” It should be noted, however, that an n.o.s. description as a proper shipping name may not provide sufficient information for shipping papers and package markings. Under the provisions of subparts C and D of this part, the technical name of one or more constituents which makes the product a hazardous material may be required in association with the proper shipping name.

* * * * *

§172.102 Special provisions.

* * * * *

(c) * * *

(1) * * *

(78) This entry may not be used to describe compressed air which contains more than 23.5 percent oxygen. Compressed air containing greater than 23.5 percent oxygen must be shipped using the description ‘‘Compressed gas, oxidizing, n.o.s., UN3156.’’

* * * * *

(156) Asbestos that is immersed or fixed in a natural or artificial binder material, such as cement, plastic, asphalt, resins or mineral ore, or contained in manufactured products is not subject to the requirements of this subchapter.

* * * * *

(387) When materials are stabilized by temperature control, the provisions of §173.21(f) of this subchapter apply. When chemical stabilization is employed, the person offering the material for transport shall ensure that the level of stabilization is sufficient to prevent the material as packaged from dangerous polymerization at 50°C (122°F). If chemical stabilization becomes ineffective at lower temperatures within the anticipated duration of transport, temperature control is required and is forbidden by aircraft. In making this determination factors to be taken into consideration include, but are not limited to, the capacity and geometry of the packaging and the effect of any insulation present, the temperature of the material when offered for transport, the duration of the journey, and the ambient temperature conditions typically encountered in the journey (considering also the season of year), the effectiveness and other properties of the stabilizer employed, applicable operational controls imposed by regulation (e.g., requirements to protect from sources of heat, including other cargo carried at a temperature above ambient) and any other relevant factors. The provisions of this special provision will be effective until January 2, 2023, unless we terminate them earlier or extend them beyond that date by notice of a final rule in the Federal Register.

* * * * *

(421) This entry will no longer be effective on January 2, 2023, unless we terminate it earlier or extend it beyond that date by notice of a final rule in the Federal Register.

* * * * *

(2) * * *

A54 Irrespective of the quantity limits in Column 9B of the §172.101 table, a lithium battery, including a lithium battery packed with, or contained in, equipment that otherwise meets the applicable requirements of §173.185, may have a mass exceeding 35 kg if approved by the Associate Administrator prior to shipment.

* * * * *

(4) * * *

IP15 For UN2031 with more than 55% nitric acid, the permitted use of rigid plastic IBCs, and the inner receptacle of composite IBCs with rigid plastics, shall be two years from their date of manufacture.

* * * * *

§173.4b De minimis exceptions.

* * * * *

(b) * * *

(1) The specimens are:

(i) Wrapped in a paper towel or cheesecloth moistened with alcohol or an alcohol solution and placed in a plastic bag that is heat-sealed. Any free liquid in the bag must not exceed 30 mL; or

(ii) Placed in vials or other rigid containers with no more than 30 mL of alcohol or alcohol solution. The containers are placed in a plastic bag that is heat-sealed;

* * * * *

§173.21 Forbidden materials and packages.

* * * * *

(f) A package containing a material which is likely to decompose with a self-accelerated decomposition temperature (SADT) of 50°C (122 °F) or less, or polymerize at a temperature of 54°C (130 °F) or less with an evolution of a dangerous quantity of heat or gas when decomposing or polymerizing, unless the material is stabilized or inhibited in a manner to preclude such evolution. The SADT may be determined by any of the test methods described in Part II of the UN Manual of Tests and Criteria (IBR, see §171.7 of this subchapter).

(1) A package meeting the criteria of paragraph (f) of this section may be required to be shipped under controlled temperature conditions. The control temperature and emergency temperature for a package shall be as specified in the table in this paragraph based upon the SADT of the material. The control temperature is the temperature above which a package of the material may not be offered for transportation or transported. The emergency temperature is the temperature at which, due to imminent danger, emergency measures must be initiated.

Table 1 to Paragraph (f)(1)—Method of Determining Control and Emergency Temperature
SADT 1 Control temperatures Emergency temperature
SADT ≤20°C (68°F) 20°C (36°F) below SADT 10°C (18°F) below SADT.
20°C (68°F) <SADT ≤35°C (95°F) 15°C (27°F) below SADT 10°C (18°F) below SADT.
35°C (95°F) <SADT ≤50°C (122°F) 10°C (18°F) below SADT 5°C (9°F) below SADT.
50°C (122°F) <SADT (2) (2)
1 Self-accelerating decomposition temperature.
2 Temperature control not required.

(2) For self-reactive materials listed in §173.224(b) Table control and emergency temperatures, where required are shown in Columns 5 and 6, respectively. For organic peroxides listed in The Organic Peroxides Table in §173.225 control and emergency temperatures, where required, are shown in Columns 7a and 7b, respectively.

* * * * *

§173.27 General requirements for transportation by aircraft.

* * * * *

(f) * * *

(2) * * *

(i) * * *

(D) Divisions 4.1 (self-reactive), 4.2 (spontaneously combustible) (primary or subsidiary risk), and 4.3 (dangerous when wet) (liquids);

* * * * *

§173.124 Class 4, Divisions 4.1, 4.2 and 4.3— Definitions.

(a) * * *

(4) * * *

(iv) The provisions concerning polymerizing substances in paragraph (a)(4) will be effective until January 2, 2023.

* * * * *

§173.137 Class 8—Assignment of packing group.

The packing group of a Class 8 material is indicated in Column 5 of the §172.101 Table. When the §172.101 Table provides more than one packing group for a Class 8 material, the packing group must be determined using data obtained from tests conducted in accordance with the OECD Guidelines for the Testing of Chemicals, Test No. 435, “ In Vitro Membrane Barrier Test Method for Skin Corrosion” (IBR, see §171.7 of this subchapter) or Test No. 404, “Acute Dermal Irritation/Corrosion” (IBR, see §171.7 of this subchapter). A material that is determined not to be corrosive in accordance with OECD Guideline for the Testing of Chemicals, Test No. 430, “ In Vitro Skin Corrosion: Transcutaneous Electrical Resistance Test (TER)” (IBR, see §171.7 of this subchapter) or Test No. 431, “ In Vitro Skin Corrosion: Reconstructed Human Epidermis (RHE) Test Method” (IBR, see §171.7 of this subchapter) may be considered not to be corrosive to human skin for the purposes of this subchapter without further testing. However, a material determined to be corrosive in accordance with Test No. 430 must be further tested using Test No. 435 or Test No. 404. If the in vitro test results indicate that the substance or mixture is corrosive, but the test method does not clearly distinguish between assignment of packing groups II and III, the material may be considered to be in packing group II without further testing. The packing group assignment using data obtained from tests conducted in accordance with OECD Guideline Test No. 404 or Test No. 435 must be as follows:

* * * * *

§173.151 Exceptions for Class 4.

* * * * *

(d) Limited quantities of Division 4.3. Limited quantities of dangerous when wet solids (Division 4.3) in Packing Groups II and III are excepted from labeling requirements, unless the material is offered for transportation or transported by aircraft, and are excepted from the specification packaging requirements of this subchapter when packaged in combination packagings according to this paragraph. For transportation by aircraft, the package must also conform to applicable requirements of §173.27 of this part (e.g., authorized materials, inner packaging quantity limits and closure securement) and only hazardous material authorized aboard passenger-carrying aircraft may be transported as a limited quantity. A limited quantity package that conforms to the provisions of this section is not subject to the shipping paper requirements of subpart C of part 172 of this subchapter, unless the material meets the definition of a hazardous substance, hazardous waste, marine pollutant, or is offered for transportation and transported by aircraft or vessel. In addition, shipments of limited quantities are not subject to subpart F (Placarding) of part 172 of this subchapter. Each package must conform to the packaging requirements of subpart B of this part and may not exceed 30 kg (66 pounds) gross weight. Except for transportation by aircraft, the following combination packagings are authorized:

* * * * *

§173.167 Consumer commodities.

(a) Effective January 1, 2013, a “consumer commodity” (see §171.8 of this subchapter) when offered for transportation by aircraft may only include articles or substances of Class 2 (non-toxic aerosols only), Class 3 (Packing Group II and III only), Division 6.1 (Packing Group III only), UN3077, UN3082, UN3175, UN3334, and UN3335, provided such materials do not have a subsidiary risk and are authorized aboard a passenger-carrying aircraft. Consumer commodities are excepted from the specification outer packaging requirements of this subchapter. Packages prepared under the requirements of this section are excepted from labeling and shipping papers when transported by highway or rail. Except as indicated in §173.24(i), each completed package must conform to §§173.24 and 173.24a of this subchapter. Additionally, except for the pressure differential requirements in §173.27(c), the requirements of §173.27 do not apply to packages prepared in accordance with this section. Packages prepared under the requirements of this section may be offered for transportation and transported by all modes. As applicable, the following apply:

(1) Inner and outer packaging quantity limits. (i) Non-toxic aerosols, as defined in §171.8 of this subchapter and constructed in accordance with §173.306 of this part, in non-refillable, non-metal containers not exceeding 120 mL (4 fluid ounces) each, or in non-refillable metal containers not exceeding 820 mL (28 ounces) each, except that flammable aerosols may not exceed 500 mL (16.9 ounces) each;

(ii) Liquids, in inner packagings not exceeding 500 mL (16.9 ounces) each. Liquids must not completely fill an inner packaging at 55°C;

(iii) Solids, in inner packagings not exceeding 500 g (1.0 pounds) each; or

(iv) Any combination thereof not to exceed 30 kg (66 pounds) gross weight as prepared for shipment.

(2) Closures. Friction-type closures must be secured by positive means. The body and closure of any packaging must be constructed so as to be able to adequately resist the effects of temperature and vibration occurring in conditions normally incident to air transportation. The closure device must be so designed that it is unlikely that it can be incorrectly or incompletely closed.

(3) Absorbent material. Inner packagings must be tightly packaged in strong outer packagings. Absorbent and cushioning material must not react dangerously with the contents of inner packagings. Glass or earthenware inner packagings containing liquids of Class 3 or Division 6.1, sufficient absorbent material must be provided to absorb the entire contents of the largest inner packaging contained in the outer packaging. Absorbent material is not required if the glass or earthenware inner packagings are sufficiently protected as packaged for transport that it is unlikely a failure would occur and, if a failure did occur, that it would be unlikely that the contents would leak from the outer packaging.

(4) Drop test capability. Breakable inner packagings (e.g., glass, earthenware, or brittle plastic) must be packaged to prevent failure under conditions normally incident to transport. Packages of consumer commodities as prepared for transport must be capable of withstanding a 1.2 m drop on solid concrete in the position most likely to cause damage. In order to pass the test, the outer packaging must not exhibit any damage liable to affect safety during transport and there must be no leakage from the inner packaging(s).

(5) Stack test capability. Packages of consumer commodities must be capable of withstanding, without failure or leakage of any inner packaging and without any significant reduction in effectiveness, a force applied to the top surface for a duration of 24 hours equivalent to the total weight of identical packages if stacked to a height of 3.0 m (including the test sample).

(b) When offered for transportation by aircraft:

(1) Packages prepared under the requirements of this section are to be marked as a limited quantity in accordance with §172.315(b)(1) and labeled as a Class 9 article or substance, as appropriate, in accordance with subpart E of part 172 of this subchapter; and

(2) Pressure differential capability: Except for UN3082, inner packagings intended to contain liquids must be capable of meeting the pressure differential requirements (75 kPa) prescribed in §173.27(c) of this part. The capability of a packaging to withstand an internal pressure without leakage that produces the specified pressure differential should be determined by successfully testing design samples or prototypes.

§173.185 Lithium cells and batteries.

* * * * *

(a) * * *

(3) Beginning January 1, 2022 each manufacturer and subsequent distributor of lithium cells or batteries manufactured on or after January 1, 2008, must make available a test summary. The test summary must include the following elements:

* * * * *

* * * * *

(ix) Reference to the revised edition of the UN Manual of Tests and Criteria used and to amendments thereto, if any; and

* * * * *

(b) * * *

(3) * * *

(iii) * * *

(A) Be placed in inner packagings that completely enclose the cell or battery, then placed in an outer packaging. The completed package for the cells or batteries must meet the Packing Group II performance requirements as specified in paragraph (b)(3)(ii) of this section; or

(B) Be placed in inner packagings that completely enclose the cell or battery, then placed with equipment in a package that meets the Packing Group II performance requirements as specified in paragraph (b)(3)(ii) of this section.

* * * * *

(4) * * *

(ii) Equipment must be secured to prevent damage caused by shifting within the outer packaging and be packed so as to prevent accidental operation during transport; and

(iii) Any spare lithium cells or batteries packed with the equipment must be packaged in accordance with paragraph (b)(3) of this section.

* * * * *

(5) Lithium batteries that weigh 12 kg (26.5 pounds) or more and have a strong, impact-resistant outer casing may be packed in strong outer packagings; in protective enclosures (for example, in fully enclosed or wooden slatted crates); or on pallets or other handling devices, instead of packages meeting the UN performance packaging requirements in paragraphs (b)(3)(ii) and (iii) of this section. Batteries must be secured to prevent inadvertent shifting, and the terminals may not support the weight of other superimposed elements. Batteries packaged in accordance with this paragraph may be transported by cargo aircraft if approved by the Associate Administrator.

* * * * *

(c) * * *

(3) Lithium battery mark. Each package must display the lithium battery mark except when a package contains only button cell batteries contained in equipment (including circuit boards), or when a consignment contains two packages or fewer where each package contains not more than four lithium cells or two lithium batteries contained in equipment. [Change Notice][Previous Text]

(i) The mark must indicate the UN number: “UN3090” for lithium metal cells or batteries; or “UN3480” for lithium ion cells or batteries. Where the lithium cells or batteries are contained in, or packed with, equipment, the UN number “UN3091” or “UN3481,” as appropriate, must be indicated. Where a package contains lithium cells or batteries assigned to different UN numbers, all applicable UN numbers must be indicated on one or more marks. The package must be of such size that there is adequate space to affix the mark on one side without the mark being folded.



(A) The mark must be in the form of a rectangle or a square with hatched edging. The mark must be not less than 100 mm (3.9 inches) wide by 100 mm (3.9 inches) high and the minimum width of the hatching must be 5 mm (0.2 inches), except marks of 100 mm (3.9 inches) wide by 70 mm (2.8 inches) high may be used on a package containing lithium batteries when the package is too small for the larger mark;

(B) The symbols and letters must be black on white or suitable contrasting background and the hatching must be red;

(C) The “*” must be replaced by the appropriate UN number(s) and the “**” must be replaced by a telephone number for additional information; and

(D) Where dimensions are not specified, all features shall be in approximate proportion to those shown.

(ii) [Reserved]

(iii) When packages are placed in an overpack, the lithium battery mark shall either be clearly visible through the overpack or be reproduced on the outside of the overpack and the overpack shall be marked with the word “OVERPACK”. The lettering of the “OVERPACK” mark shall be at least 12 mm (0.47 inches) high.

(4) Air transportation. (i) For transportation by aircraft, lithium cells and batteries may not exceed the limits in the following Table 1 to paragraph (c)(4)(i). The limits on the maximum number of batteries and maximum net quantity of batteries in the following table may not be combined in the same package. The limits in the following table do not apply to lithium cells and batteries packed with, or contained in, equipment.

Table 1 to Paragraph (c)(4)(i)
Contents Lithium metal cells and/or batteries with a lithium content not more than 0.3 g Lithium metal cells with a lithium content more than 0.3 g but not more than 1 g Lithium metal batteries with a lithium content more than 0.3 g but not more than 2 g Lithium ion cells and/or batteries with a watt-hour rating not more than 2.7 Wh Lithium ion cells with a watt-hour rating more than 2.7 Wh but not more than 20 Wh Lithium ion batteries with a watt-hour rating more than 2.7 Wh but not more than 100 Wh
Maximum number of cells/batteries per package No Limit 8 cells 2 batteries No Limit 8 cells 2 batteries.
Maximum net quantity (mass) per package 2.5 kg n/a n/a 2.5 kg n/a n/a.

(ii) Not more than one package prepared in accordance with paragraph (c)(4)(i) of this section may be placed into an overpack.

(iii) A shipper is not permitted to offer for transport more than one package prepared in accordance with the provisions of paragraph (c)(4)(i) of this section in any single consignment.

(iv) Each shipment with packages required to display the paragraph (c)(3)(i) lithium battery mark must include an indication on the air waybill of compliance with this paragraph (c)(4) (or the applicable ICAO Technical Instructions Packing Instruction), when an air waybill is used.

(v) Packages and overpacks of lithium batteries prepared in accordance with paragraph (c)(4)(i) of this section must be offered to the operator separately from cargo which is not subject to the requirements of this subchapter and must not be loaded into a unit load device before being offered to the operator.

(vi) For lithium batteries packed with, or contained in, equipment, the number of batteries in each package is limited to the minimum number required to power the piece of equipment, plus two spare sets, and the total net quantity (mass) of the lithium cells or batteries in the completed package must not exceed 5 kg. A “set” of cells or batteries is the number of individual cells or batteries that are required to power each piece of equipment.

(vii) Each person who prepares a package for transport containing lithium cells or batteries, including cells or batteries packed with, or contained in, equipment in accordance with the conditions and limitations of this paragraph (c)(4), must receive instruction on these conditions and limitations, corresponding to their functions.

(viii) Lithium cells and batteries must not be packed in the same outer packaging with other hazardous materials. Packages prepared in accordance with paragraph (c)(4)(i) of this section must not be placed into an overpack with packages containing hazardous materials and articles of Class 1 (explosives) other than Division 1.4S, Division 2.1 (flammable gases), Class 3 (flammable liquids), Division 4.1 (flammable solids), or Division 5.1 (oxidizers).

(5) For transportation by aircraft, a package that exceeds the number or quantity (mass) limits in the table shown in paragraph (c)(4)(i) of this section, the overpack limit described in paragraph (c)(4)(ii) of this section, or the consignment limit described in paragraph (c)(4)(iii) of this section is subject to all applicable requirements of this subchapter, except that a package containing no more than 2.5 kg lithium metal cells or batteries or 10 kg lithium ion cells or batteries is not subject to the UN performance packaging requirements in paragraph (b)(3)(ii) of this section when the package displays both the lithium battery mark in paragraph (c)(3)(i) and the Class 9 Lithium Battery label specified in §172.447 of this subchapter. This paragraph does not apply to batteries or cells packed with or contained in equipment.

* * * * *

(e) * * *

(5) Lithium batteries, including lithium batteries contained in equipment, that weigh 12 kg (26.5 pounds) or more and have a strong, impact-resistant outer casing may be packed in strong outer packagings, in protective enclosures (for example, in fully enclosed or wooden slatted crates), or on pallets or other handling devices, instead of packages meeting the UN performance packaging requirements in paragraphs (b)(3)(ii) and (iii) of this section. The battery must be secured to prevent inadvertent shifting, and the terminals may not support the weight of other superimposed elements;

(6) Irrespective of the limit specified in column (9B) of the §172.101 Hazardous Materials Table, the battery or battery assembly prepared for transport in accordance with this paragraph may have a mass exceeding 35 kg gross weight when transported by cargo aircraft;

(7) Batteries or battery assemblies packaged in accordance with this paragraph are not permitted for transportation by passenger-carrying aircraft, and may be transported by cargo aircraft only if approved by the Associate Administrator prior to transportation; and

* * * * *

§173.224 Packaging and control and emergency temperatures for self-reactive materials.

* * * * *

(b) * * *

(4) Packing method. Column 4 specifies the highest packing method which is authorized for the self-reactive material. A packing method corresponding to a smaller package size may be used, but a packing method corresponding to a larger package size may not be used. The Table of Packing Methods in §173.225(d) defines the packing methods. Bulk packagings for Type F self-reactive substances are authorized by §173.225(f) for IBCs and §173.225(h) for bulk packagings other than IBCs. The formulations listed in §173.225(f) for IBCs and in §173.225(g) for portable tanks may also be transported packed in accordance with packing method OP8, with the same control and emergency temperatures, if applicable. Additional bulk packagings are authorized if approved by the Associate Administrator.

* * * * *

Self-Reactive Materials Table
Self-reactive substance


(1)
Identification No.


(2)
Concentra-
tion—(%)


(3)
Packing method


(4)
Control
tempera-
ture— (°C)


(5)
Emer-
gency
tempera-
ture—


(6)
Notes


(7)
Notes:
1. The emergency and control temperatures must be determined in accordance with §173.21(f).
2. With a compatible diluent having a boiling point of not less than 150 °C.
3. Samples may only be offered for transportation under the provisions of paragraph (c)(3) of this section.
4. This entry applies to mixtures of esters of 2-diazo-1-naphthol-4-sulphonic acid and 2-diazo-1-naphthol-5-sulphonic acid.
5. This entry applies to the technical mixture in n-butanol within the specified concentration limits of the (Z) isomer.
Acetone-pyrogallol copolymer 2-diazo-1-naphthol-5-sulphonate 3228 100 OP8
Azodicarbonamide formulation type B, temperature controlled 3232 <100 OP5 1
Azodicarbonamide formulation type C 3224 <100 OP6
Azodicarbonamide formulation type C, temperature controlled 3234 <100 OP6 1
Azodicarbonamide formulation type D 3226 <100 OP7
Azodicarbonamide formulation type D, temperature controlled 3236 <100 OP7 1
2,2′-Azodi(2,4-dimethyl-4-methoxyvaleronitrile) 3236 100 OP7 −5 +5
2,2′-Azodi(2,4-dimethylvaleronitrile) 3236 100 OP7 +10 +15
2,2′-Azodi(ethyl 2-methylpropionate) 3235 100 OP7 +20 +25
1,1-Azodi(hexahydrobenzonitrile) 3226 100 OP7
2,2-Azodi(isobutyronitrile) 3234 100 OP6 +40 +45
2,2′-Azodi(isobutyronitrile) as a water based paste 3224 ≤50 OP6
2,2-Azodi(2-methylbutyronitrile) 3236 100 OP7 +35 +40
Benzene-1,3-disulphonylhydrazide, as a paste 3226 52 OP7
Benzene sulphohydrazide 3226 100 OP7
4-(Benzyl(ethyl)amino)-3-ethoxybenzenediazonium zinc chloride 3226 100 OP7
4-(Benzyl(methyl)amino)-3-ethoxybenzenediazonium zinc chloride 3236 100 OP7 +40 +45
3-Chloro-4-diethylaminobenzenediazonium zinc chloride 3226 100 OP7
2-Diazo-1-Naphthol sulphonic acid ester mixture 3226 <100 OP7 4
2-Diazo-1-Naphthol-4-sulphonyl chloride 3222 100 OP5
2-Diazo-1-Naphthol-5-sulphonyl chloride 3222 100 OP5
2,5-Dibutoxy-4-(4-morpholinyl)-Benzenediazonium, tetrachlorozincate (2:1) 3228 100 OP8
2,5-Diethoxy-4-morpholinobenzenediazonium zinc chloride 3236 67−100 OP7 +35 +40
2,5-Diethoxy-4-morpholinobenzenediazonium zinc chloride 3236 66 OP7 +40 +45
2,5-Diethoxy-4-morpholinobenzenediazonium tetrafluoroborate 3236 100 OP7 +30 +35
2,5-Diethoxy-4-(phenylsulphonyl)benzenediazonium zinc chloride 3236 67 OP7 +40 +45
2,5-Diethoxy-4-(4-morpholinyl)-benzenediazonium sulphate 3226 100 OP7
Diethylene glycol bis(allyl carbonate) + Diisopropylperoxydicarbonate 3237 ≥88 + ≤12 OP8 −10 0
2,5-Dimethoxy-4-(4-methylphenylsulphony)benzenediazonium zinc chloride 3236 79 OP7 +40 +45
4-Dimethylamino-6-(2-dimethylaminoethoxy)toluene-2-diazonium zinc chloride 3236 100 OP7 +40 +45
4-(Dimethylamino)-benzenediazonium trichlorozincate (-1) 3228 100 OP8
N,N′-Dinitroso-N, N′-dimethyl-terephthalamide, as a paste 3224 72 OP6
N,N′-Dinitrosopentamethylenetetramine 3224 82 OP6 2
Diphenyloxide-4,4′-disulphohydrazide 3226 100 OP7
Diphenyloxide-4,4′-disulphonylhydrazide 3226 100 OP7
4-Dipropylaminobenzenediazonium zinc chloride 3226 100 OP7
2-(N,N-Ethoxycarbonylphenylamino)-3-methoxy-4-(N-methyl-N- cyclohexylamino)benzenediazonium zinc chloride 3236 63−92 OP7 +40 +45
2-(N,N-Ethoxycarbonylphenylamino)-3-methoxy-4-(N-methyl-N- cyclohexylamino)benzenediazonium zinc chloride 3236 62 OP7 +35 +40
N-Formyl-2-(nitromethylene)-1,3-perhydrothiazine 3236 100 OP7 +45 +50
2-(2-Hydroxyethoxy)-1-(pyrrolidin-1-yl)benzene-4-diazonium zinc chloride 3236 100 OP7 +45 +50
3-(2-Hydroxyethoxy)-4-(pyrrolidin-1-yl)benzenediazonium zinc chloride 3236 100 OP7 +40 +45
2-(N,N-Methylaminoethylcarbonyl)-4-(3,4-dimethyl-phenylsulphonyl)benzene diazonium zinc chloride 3236 96 OP7 +45 +50
4-Methylbenzenesulphonylhydrazide 3226 100 OP7
3-Methyl-4-(pyrrolidin-1-yl)benzenediazonium tetrafluoroborate 3234 95 OP6 +45 +50
4-Nitrosophenol 3236 100 OP7 +35 +40
Phosphorothioic acid, O-[(cyanophenyl methylene) azanyl] O,O-diethyl ester 3227 82−91 (Z isomer) OP8 5
Self-reactive liquid, sample 3223 OP2 3
Self-reactive liquid, sample, temperature control 3233 OP2 3
Self-reactive solid, sample 3224 OP2 3
Self-reactive solid, sample, temperature control 3234 OP2 3
Sodium 2-diazo-1-naphthol-4-sulphonate 3226 100 OP7
Sodium 2-diazo-1-naphthol-5-sulphonate 3226 100 OP7
Tetramine palladium (II) nitrate 3234 100 OP6 +30 +35

§173.225 Packaging requirements and other provisions for organic peroxides.

* * * * *

(c) * * *

Table 1 to Paragraph (c)—Organic Peroxide Table
Technical name ID No. Concentration (mass %) Diluent (mass %) Water (mass %) Packing method Temperature (°C) Notes
A B I Control Emergency
(1) (2) (3) (4a) (4b) (4c) (5) (6) (7a) (7b) (8)
Acetyl acetone peroxide UN3105 ≤42 ≥48 ≥8 OP7 2
Acetyl acetone peroxide [as a paste] UN3106 ≤32 OP7 21
Acetyl cyclohexanesulfonyl peroxide UN3112 ≤82 ≥12 OP4 −10 0
Acetyl cyclohexanesulfonyl peroxide UN3115 ≤32 ≥68 OP7 −10 0
tert-Amyl hydroperoxide UN3107 ≤88 ≥6 ≥6 OP8
tert-Amyl peroxyacetate UN3105 ≤62 ≥38 OP7
tert-Amyl peroxybenzoate UN3103 ≤100 OP5
tert-Amyl peroxy-2-ethylhexanoate UN3115 ≤100 OP7 +20 +25
tert-Amyl peroxy-2-ethylhexyl carbonate UN3105 ≤100 OP7
tert-Amyl peroxy isopropyl carbonate UN3103 ≤77 ≥23 OP5
tert-Amyl peroxyneodecanoate UN3115 ≤77 ≥23 OP7 0 +10
tert-Amyl peroxyneodecanoate UN3119 ≤47 ≥53 OP8 0 +10
tert-Amyl peroxypivalate UN3113 ≤77 ≥23 OP5 +10 +15
tert-Amyl peroxypivalate UN3119 ≤32 ≥68 OP8 +10 +15
tert-Amyl peroxy-3,5,5-trimethylhexanoate UN3105 ≤100 OP7
tert-Butyl cumyl peroxide UN3109 >42−100 OP8 9
tert-Butyl cumyl peroxide UN3108 ≤52 ≥48 OP8 9
n-Butyl-4,4-di-(tert-butylperoxy)valerate UN3103 >52−100 OP5
n-Butyl-4,4-di-(tert-butylperoxy)valerate UN3108 ≤52 ≥48 OP8
tert-Butyl hydroperoxide UN3103 >79−90 ≥10 OP5 13
tert-Butyl hydroperoxide UN3105 ≤80 ≥20 OP7 4, 13
tert-Butyl hydroperoxide UN3107 ≤79 >14 OP8 13, 16
tert-Butyl hydroperoxide UN3109 ≤72 ≥28 OP8 13
tert-Butyl hydroperoxide [and] Di-tert-butylperoxide UN3103 <82 + >9 ≥7 OP5 13
tert-Butyl monoperoxymaleate UN3102 >52−100 OP5
tert-Butyl monoperoxymaleate UN3103 ≤52 ≥48 OP6
tert-Butyl monoperoxymaleate UN3108 ≤52 ≥48 OP8
tert-Butyl monoperoxymaleate [as a paste] UN3108 ≤52 OP8
tert-Butyl peroxyacetate UN3101 >52−77 ≥23 OP5
tert-Butyl peroxyacetate UN3103 >32−52 ≥48 OP6
tert-Butyl peroxyacetate UN3109 ≤32 ≥68 OP8
tert-Butyl peroxybenzoate UN3103 >77−100 OP5
tert-Butyl peroxybenzoate UN3105 >52−77 ≥23 OP7 1
tert-Butyl peroxybenzoate UN3106 ≤52 ≥48 OP7
tert-Butyl peroxybenzoate UN3109 ≤32 ≥68 OP8
tert-Butyl peroxybutyl fumarate UN3105 ≤52 ≥48 OP7
tert-Butyl peroxycrotonate UN3105 ≤77 ≥23 OP7
tert-Butyl peroxydiethylacetate UN3113 ≤100 OP5 +20 +25
tert-Butyl peroxy-2-ethylhexanoate UN3113 >52−100 OP6 +20 +25
tert-Butyl peroxy-2-ethylhexanoate UN3117 >32−52 ≥48 OP8 +30 +35
tert-Butyl peroxy-2-ethylhexanoate UN3118 ≤52 ≥48 OP8 +20 +25
tert-Butyl peroxy-2-ethylhexanoate UN3119 ≤32 ≥68 OP8 +40 +45
tert-Butyl peroxy-2-ethylhexanoate [and] 2,2-di-(tert-Butylperoxy)butane UN3106 ≤12 + ≤14 ≥14 ≥60 OP7
tert-Butyl peroxy-2-ethylhexanoate [and] 2,2-di-(tert-Butylperoxy)butane UN3115 ≤31 + ≤36 ≥33 OP7 +35 +40
tert-Butyl peroxy-2-ethylhexylcarbonate UN3105 ≤100 OP7
tert-Butyl peroxyisobutyrate UN3111 >52−77 ≥23 OP5 +15 +20
tert-Butyl peroxyisobutyrate UN3115 ≤52 ≥48 OP7 +15 +20
tert-Butylperoxy isopropylcarbonate UN3103 ≤77 ≥23 OP5
1-(2-tert-Butylperoxy isopropyl)-3-isopropenylbenzene UN3105 ≤77 ≥23 OP7
1-(2-tert-Butylperoxy isopropyl)-3-isopropenylbenzene UN3108 ≤42 ≥58 OP8
tert-Butyl peroxy-2-methylbenzoate UN3103 ≤100 OP5
tert-Butyl peroxyneodecanoate UN3115 >77−100 OP7 −5 +5
tert-Butyl peroxyneodecanoate UN3115 ≤77 ≥23 OP7 0 +10
tert-Butyl peroxyneodecanoate [as a stable dispersion in water] UN3119 ≤52 OP8 0 +10
tert-Butyl peroxyneodecanoate [as a stable dispersion in water (frozen)] UN3118 ≤42 OP8 0 +10
tert-Butyl peroxyneodecanoate UN3119 ≤32 ≥68 OP8 0 +10
tert-Butyl peroxyneoheptanoate UN3115 ≤77 ≥23 OP7 0 +10
tert-Butyl peroxyneoheptanoate [as a stable dispersion in water] UN3117 ≤42 OP8 0 +10
tert-Butyl peroxypivalate UN3113 >67−77 ≥23 OP5 0 +10
tert-Butyl peroxypivalate UN3115 >27−67 ≥33 OP7 0 +10
tert-Butyl peroxypivalate UN3119 ≤27 ≥73 OP8 +30 +35
tert-Butylperoxy stearylcarbonate UN3106 ≤100 OP7
tert-Butyl peroxy-3,5,5-trimethylhexanoate UN3105 >37−100 OP7
tert-Butyl peroxy-3,5,5-trimethlyhexanoate UN3106 ≤42 ≥58 OP7
tert-Butyl peroxy-3,5,5-trimethylhexanoate UN3109 ≤37 ≥63 OP8
3-Chloroperoxybenzoic acid UN3102 >57−86 ≥14 OP1
3-Chloroperoxybenzoic acid UN3106 ≤57 ≥3 ≥40 OP7
3-Chloroperoxybenzoic acid UN3106 ≤77 ≥6 ≥17 OP7
Cumyl hydroperoxide UN3107 >90−98 ≤10 OP8 13
Cumyl hydroperoxide UN3109 ≤90 ≥10 OP8 13, 15
Cumyl peroxyneodecanoate UN3115 ≤87 ≥13 OP7 −10 0
Cumyl peroxyneodecanoate UN3115 ≤77 ≥23 OP7 −10 0
Cumyl peroxyneodecanoate [as a stable dispersion in water] UN3119 ≤52 OP8 −10 0
Cumyl peroxyneoheptanoate UN3115 ≤77 ≥23 OP7 −10 0
Cumyl peroxypivalate UN3115 ≤77 ≥23 OP7 −5 +5
Cyclohexanone peroxide(s) UN3104 ≤91 ≥9 OP6 13
Cyclohexanone peroxide(s) UN3105 ≤72 ≥28 OP7 5
Cyclohexanone peroxide(s) [as a paste] UN3106 ≤72 OP7 5, 21
Cyclohexanone peroxide(s) Exempt ≤32 >68 Exempt 29
Diacetone alcohol peroxides UN3115 ≤57 ≥26 ≥8 OP7 +40 +45 5
Diacetyl peroxide UN3115 ≤27 ≥73 OP7 +20 +25 8,13
Di-tert-amyl peroxide UN3107 ≤100 OP8
([3R- (3R, 5aS, 6S, 8aS, 9R, 10R, 12S, 12aR**)]-Decahydro-10-methoxy-3, 6, 9-trimethyl-3, 12-epoxy-12H-pyrano [4, 3- j]-1, 2-benzodioxepin) UN3106 ≤100 OP7
2,2-Di-(tert-amylperoxy)-butane UN3105 ≤57 ≥43 OP7
1,1-Di-(tert-amylperoxy)cyclohexane UN3103 ≤82 ≥18 OP6
Dibenzoyl peroxide UN3102 >52−100 ≤48 OP2 3
Dibenzoyl peroxide UN3102 >77−94 ≥6 OP4 3
Dibenzoyl peroxide UN3104 ≤77 ≥23 OP6
Dibenzoyl peroxide UN3106 ≤62 ≥28 ≥10 OP7
Dibenzoyl peroxide [as a paste] UN3106 >52−62 OP7 21
Dibenzoyl peroxide UN3106 >35−52 ≥48 OP7
Dibenzoyl peroxide UN3107 >36−42 ≥18 ≤40 OP8
Dibenzoyl peroxide [as a paste] UN3108 ≤56.5 ≥15 OP8
Dibenzoyl peroxide [as a paste] UN3108 ≤52 OP8 21
Dibenzoyl peroxide [as a stable dispersion in water] UN3109 ≤42 OP8
Dibenzoyl peroxide Exempt ≤35 ≥65 Exempt 29
Di-(4-tert-butylcyclohexyl)peroxydicarbonate UN3114 ≤100 OP6 +30 +35
Di-(4-tert-butylcyclohexyl)peroxydicarbonate [as a stable dispersion in water] UN3119 ≤42 OP8 +30 +35
Di-(4-tert-butylcyclohexyl)peroxydicarbonate [as a paste] UN3116 ≤42 OP7 +35 +40
Di-tert-butyl peroxide UN3107 >52−100 OP8
Di-tert-butyl peroxide UN3109 ≤52 ≥48 OP8 24
Di-tert-butyl peroxyazelate UN3105 ≤52 ≥48 OP7
2,2-Di-(tert-butylperoxy)butane UN3103 ≤52 ≥48 OP6
1,6-Di-(tert-butylperoxycarbonyloxy)hexane UN3103 ≤72 ≥28 OP5
1,1-Di-(tert-butylperoxy)cyclohexane UN3101 >80−100 OP5
1,1-Di-(tert-butylperoxy)cyclohexane UN3103 >52−80 ≥20 OP5
1,1-Di-(tert-butylperoxy)-cyclohexane UN3103 ≤72 ≥28 OP5 30
1,1-Di-(tert-butylperoxy)cyclohexane UN3105 >42−52 ≥48 OP7
1,1-Di-(tert-butylperoxy)cyclohexane UN3106 ≤42 ≥13 ≥45 OP7
1,1-Di-(tert-butylperoxy)cyclohexane UN3107 ≤27 ≥25 OP8 22
1,1-Di-(tert-butylperoxy)cyclohexane UN3109 ≤42 ≥58 OP8
1,1-Di-(tert-Butylperoxy) cyclohexane UN3109 ≤37 ≥63 OP8
1,1-Di-(tert-butylperoxy)cyclohexane UN3109 ≤25 ≥25 ≥50 OP8
1,1-Di-(tert-butylperoxy)cyclohexane UN3109 ≤13 ≥13 ≥74 OP8
1,1-Di-(tert-butylperoxy)cyclohexane + tert-Butyl peroxy-2-ethylhexanoate UN3105 ≤43 + ≤16 ≥41 OP7
Di-n-butyl peroxydicarbonate UN3115 >27−52 ≥48 OP7 −15 −5
Di-n-butyl peroxydicarbonate UN3117 ≤27 ≥73 OP8 −10 0
Di-n-butyl peroxydicarbonate [as a stable dispersion in water (frozen)] UN3118 ≤42 OP8 −15 −5
Di-sec-butyl peroxydicarbonate UN3113 >52−100 OP4 −20 −10 6
Di-sec-butyl peroxydicarbonate UN3115 ≤52 ≥48 OP7 −15 −5
Di-(tert-butylperoxyisopropyl) benzene(s) UN3106 >42−100 ≤57 OP7 1, 9
Di-(tert-butylperoxyisopropyl) benzene(s) Exempt ≤42 ≥58 Exempt
Di-(tert-butylperoxy)phthalate UN3105 >42−52 ≥48 OP7
Di-(tert-butylperoxy)phthalate [as a paste] UN3106 ≤52 OP7 21
Di-(tert-butylperoxy)phthalate UN3107 ≤42 ≥58 OP8
2,2-Di-(tert-butylperoxy)propane UN3105 ≤52 ≥48 OP7
2,2-Di-(tert-butylperoxy)propane UN3106 ≤42 ≥13 ≥45 OP7
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3101 >90−100 OP5
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3103 >57−90 ≥10 OP5
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3103 ≤77 ≥23 OP5
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3103 ≤90 ≥10 OP5 30
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3110 ≤57 ≥43 OP8
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3107 ≤57 ≥43 OP8
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3107 ≤32 ≥26 ≥42 OP8
Dicetyl peroxydicarbonate UN3120 ≤100 OP8 +30 +35
Dicetyl peroxydicarbonate [as a stable dispersion in water] UN3119 ≤42 OP8 +30 +35
Di-4-chlorobenzoyl peroxide UN3102 ≤77 ≥23 OP5
Di-4-chlorobenzoyl peroxide Exempt ≤32 ≥68 Exempt 29
Di-2,4-dichlorobenzoyl peroxide [as a paste] UN3118 ≤52 OP8 +20 +25
Di-4-chlorobenzoyl peroxide [as a paste] UN3106 ≤52 OP7 21
Dicumyl peroxide UN3110 >52−100 ≤48 OP8 9
Dicumyl peroxide Exempt ≤52 ≥48 Exempt 29
Dicyclohexyl peroxydicarbonate UN3112 >91−100 OP3 +10 +15
Dicyclohexyl peroxydicarbonate UN3114 ≤91 ≥9 OP5 +10 +15
Dicyclohexyl peroxydicarbonate [as a stable dispersion in water] UN3119 ≤42 OP8 +15 +20
Didecanoyl peroxide UN3114 ≤100 OP6 +30 +35
2,2-Di-(4,4-di(tert-butylperoxy)cyclohexyl)propane UN3106 ≤42 ≥58 OP7
2,2-Di-(4,4-di(tert-butylperoxy)cyclohexyl)propane UN3107 ≤22 ≥78 OP8
Di-2,4-dichlorobenzoyl peroxide UN3102 ≤77 ≥23 OP5
Di-2,4-dichlorobenzoyl peroxide [as a paste with silicone oil] UN3106 ≤52 OP7
Di-(2-ethoxyethyl) peroxydicarbonate UN3115 ≤52 ≥48 OP7 −10 0
Di-(2-ethylhexyl) peroxydicarbonate UN3113 >77−100 OP5 −20 −10
Di-(2-ethylhexyl) peroxydicarbonate UN3115 ≤77 ≥23 OP7 −15 −5
Di-(2-ethylhexyl) peroxydicarbonate [as a stable dispersion in water] UN3119 ≤62 OP8 −15 −5
Di-(2-ethylhexyl) peroxydicarbonate [as a stable dispersion in water] UN3119 ≤52 OP8 −15 −5
Di-(2-ethylhexyl) peroxydicarbonate [as a stable dispersion in water (frozen)] UN3120 ≤52 OP8 −15 −5
2,2-Dihydroperoxypropane UN3102 ≤27 ≥73 OP5
Di-(1-hydroxycyclohexyl)peroxide UN3106 ≤100 OP7
Diisobutyryl peroxide UN3111 >32−52 ≥48 OP5 −20 −10
Diisobutyryl peroxide [as a stable dispersion in water] UN3119 ≤42 OP8 −20 −10
Diisobutyryl peroxide UN3115 ≤32 ≥68 OP7 −20 −10
Diisopropylbenzene dihydroperoxie UN3106 ≤82 ≥5 ≥5 OP7 17
Diisopropyl peroxydicarbonate UN3112 >52−100 OP2 −15 −5
Diisopropyl peroxydicarbonate UN3115 ≤52 ≥48 OP7 −20 −10
Diisopropyl peroxydicarbonate UN3115 ≤32 ≥68 OP7 −15 −5
Dilauroyl peroxide UN3106 ≤100 OP7
Dilauroyl peroxide [as a stable dispersion in water] UN3109 ≤42 OP8
Di-(3-methoxybutyl) peroxydicarbonate UN3115 ≤52 ≥48 OP7 −5 +5
Di-(2-methylbenzoyl)peroxide UN3112 ≤87 ≥13 OP5 +30 +35
Di-(4-methylbenzoyl)peroxide [as a paste with silicone oil] UN3106 ≤52 OP7
Di-(3-methylbenzoyl) peroxide + Benzoyl (3-methylbenzoyl) peroxide + Dibenzoyl peroxide UN3115 ≤20 + ≤18 + ≤4 ≥58 OP7 +35 +40
2,5-Dimethyl-2,5-di-(benzoylperoxy)hexane UN3102 >82−100 OP5
2,5-Dimethyl-2,5-di-(benzoylperoxy)hexane UN3106 ≤82 ≥18 OP7
2,5-Dimethyl-2,5-di-(benzoylperoxy)hexane UN3104 ≤82 ≥18 OP5
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane UN3103 >90−100 OP5
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane UN3105 >52—90 ≥10 OP7
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane UN3108 ≤77 ≥23 OP8
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane UN3109 ≤52 ≥48 OP8
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane [as a paste] UN3108 ≤47 OP8
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexyne-3 UN3101 >86−100 OP5
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexyne-3 UN3103 >52−86 ≥14 OP5
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexyne-3 UN3106 ≤52 ≥48 OP7
2,5-Dimethyl-2,5-di-(2-ethylhexanoylperoxy)hexane UN3113 ≤100 OP5 +20 +25
2,5-Dimethyl-2,5-dihydroperoxyhexane UN3104 ≤82 ≥18 OP6
2,5-Dimethyl-2,5-di-(3,5,5-trimethylhexanoylperoxy)hexane UN3105 ≤77 ≥23 OP7
1,1-Dimethyl-3-hydroxybutylperoxyneoheptanoate UN3117 ≤52 ≥48 OP8 0 +10
Dimyristyl peroxydicarbonate UN3116 ≤100 OP7 +20 +25
Dimyristyl peroxydicarbonate [as a stable dispersion in water] UN3119 ≤42 OP8 +20 +25
Di-(2-neodecanoylperoxyisopropyl)benzene UN3115 ≤52 ≥48 OP7 −10 0
Di-(2-neodecanoyl-peroxyisopropyl) benzene, as stable dispersion in water UN3119 ≤42 OP8 −15 −5
Di-n-nonanoyl peroxide UN3116 ≤100 OP7 0 +10
Di-n-octanoyl peroxide UN3114 ≤100 OP5 +10 +15
Di-(2-phenoxyethyl)peroxydicarbonate UN3102 >85−100 OP5
Di-(2-phenoxyethyl)peroxydicarbonate UN3106 ≤85 ≥15 OP7
Dipropionyl peroxide UN3117 ≤27 ≥73 OP8 +15 +20
Di-n-propyl peroxydicarbonate UN3113 ≤100 OP3 −25 −15
Di-n-propyl peroxydicarbonate UN3113 ≤77 ≥23 OP5 −20 −10
Disuccinic acid peroxide UN3102 >72−100 OP4 18
Disuccinic acid peroxide UN3116 ≤72 ≥28 OP7 +10 +15
Di-(3,5,5-trimethylhexanoyl) peroxide UN3115 >52−82 ≥18 OP7 0 +10
Di-(3,5,5-trimethylhexanoyl)peroxide [as a stable dispersion in water] UN3119 ≤52 OP8 +10 +15
Di-(3,5,5-trimethylhexanoyl) peroxide UN3119 >38−52 ≥48 OP8 +10 +15
Di-(3,5,5-trimethylhexanoyl)peroxide UN3119 ≤38 ≥62 OP8 +20 +25
Ethyl 3,3-di-(tert-amylperoxy)butyrate UN3105 ≤67 ≥33 OP7
Ethyl 3,3-di-(tert-butylperoxy)butyrate UN3103 >77−100 OP5
Ethyl 3,3-di-(tert-butylperoxy)butyrate UN3105 ≤77 ≥23 OP7
Ethyl 3,3-di-(tert-butylperoxy)butyrate UN3106 ≤52 ≥48 OP7
1-(2-ethylhexanoylperoxy)-1,3-Dimethylbutyl peroxypivalate UN3115 ≤52 ≥45 ≥10 OP7 −20 −10
tert-Hexyl peroxyneodecanoate UN3115 ≤71 ≥29 OP7 0 +10
tert-Hexyl peroxypivalate UN3115 ≤72 ≥28 OP7 +10 +15
3-Hydroxy-1,1-dimethylbutyl peroxyneodecanoate UN3115 ≤77 ≥23 OP7 −5 +5
3-Hydroxy-1,1-dimethylbutyl peroxyneodecanoate [as a stable dispersion in water] UN3119 ≤52 OP8 −5 +5
3-Hydroxy-1,1-dimethylbutyl peroxyneodecanoate UN3117 ≤52 ≥48 OP8 −5 +5
Isopropyl sec-butyl peroxydicarbonat + Di-sec-butyl peroxydicarbonate + Di-isopropyl peroxydicarbonate UN3111 ≤52 + ≤28 + ≤22 OP5 −20 −10
Isopropyl sec-butyl peroxydicarbonate + Di-sec-butyl peroxydicarbonate + Di-isopropyl peroxydicarbonate UN3115 ≤32 + ≤15 −18 + ≤12 −15 ≥38 OP7 −20 −10
Isopropylcumyl hydroperoxide UN3109 ≤72 ≥28 OP8 13
p-Menthyl hydroperoxide UN3105 >72−100 OP7 13
p-Menthyl hydroperoxide UN3109 ≤72 ≥28 OP8
Methylcyclohexanone peroxide(s) UN3115 ≤67 ≥33 OP7 +35 +40
Methyl ethyl ketone peroxide(s) UN3101 ≤52 ≥48 OP5 5, 13
Methyl ethyl ketone peroxide(s) UN3105 ≤45 ≥55 OP7 5
Methyl ethyl ketone peroxide(s) UN3107 ≤40 ≥60 OP8 7
Methyl isobutyl ketone peroxide(s) UN3105 ≤62 ≥19 OP7 5, 23
Methyl isopropyl ketone peroxide(s) UN3109 (See remark 31) ≥70 OP8 31
Organic peroxide, liquid, sample UN3103 OP2 12
Organic peroxide, liquid, sample, temperature controlled UN3113 OP2 12
Organic peroxide, solid, sample UN3104 OP2 12
Organic peroxide, solid, sample, temperature controlled UN3114 OP2 12
3,3,5,7,7-Pentamethyl-1,2,4-Trioxepane UN3107 ≤100 OP8
Peroxyacetic acid, type D, stabilized UN3105 ≤43 OP7 13, 20
Peroxyacetic acid, type E, stabilized UN3107 ≤43 OP8 13, 20
Peroxyacetic acid, type F, stabilized UN3109 ≤43 OP8 13, 20, 28
Peroxyacetic acid or peracetic acid [with not more than 7% hydrogen peroxide] UN3107 ≤36 ≥15 OP8 13, 20, 28
Peroxyacetic acid or peracetic acid [with not more than 20% hydrogen peroxide] Exempt ≤6 ≥60 Exempt 28
Peroxyacetic acid or peracetic acid [with not more than 26% hydrogen peroxide] UN3109 ≤17 OP8 13, 20, 28
Peroxylauric acid UN3118 ≤100 OP8 +35 +40
1-Phenylethyl hydroperoxide UN3109 ≤38 ≥62 OP8
Pinanyl hydroperoxide UN3105 >56−100 OP7 13
Pinanyl hydroperoxide UN3109 ≤56 ≥44 OP8
Polyether poly-tert-butylperoxycarbonate UN3107 ≤52 ≥48 OP8
Tetrahydronaphthyl hydroperoxide UN3106 ≤100 OP7
1,1,3,3-Tetramethylbutyl hydroperoxide UN3105 ≤100 OP7
1,1,3,3-Tetramethylbutyl peroxy-2-ethylhexanoate UN3115 ≤100 OP7 +15 +20
1,1,3,3-Tetramethylbutyl peroxyneodecanoate UN3115 ≤72 ≥28 OP7 −5 +5
1,1,3,3-Tetramethylbutyl peroxyneodecanoate [as a stable dispersion in water] UN3119 ≤52 OP8 −5 +5
1,1,3,3-tetramethylbutyl peroxypivalate UN3115 ≤77 ≥23 OP7 0 +10
3,6,9-Triethyl-3,6,9-trimethyl-1,4,7-triperoxonane UN3110 ≤17 ≥18 ≥65 OP8
3,6,9-Triethyl-3,6,9-trimethyl-1,4,7-triperoxonane UN3105 ≤42 ≥58 OP7 26
Notes:
1. For domestic shipments, OP8 is authorized.
2. Available oxygen must be <4.7%.
3. For concentrations <80% OP5 is allowed. For concentrations of at least 80% but <85%, OP4 is allowed. For concentrations of at least 85%, maximum package size is OP2.
4. The diluent may be replaced by di-tert-butyl peroxide.
5. Available oxygen must be ≤9% with or without water.
6. For domestic shipments, OP5 is authorized.
7. Available oxygen must be ≤8.2% with or without water.
8. Only non-metallic packagings are authorized.
9. For domestic shipments this material may be transported under the provisions of paragraph (h)(3)(xii) of this section.
10. [Reserved]
11. [Reserved]
12. Samples may only be offered for transportation under the provisions of paragraph (b)(2) of this section.
13. “Corrosive” subsidiary risk label is required.
14. [Reserved]
15. No “Corrosive” subsidiary risk label is required for concentrations below 80%.
16. With <6% di-tert-butyl peroxide.
17. With ≤8% 1-isopropylhydroperoxy-4-isopropylhydroxybenzene.
18. Addition of water to this organic peroxide will decrease its thermal stability.
19. [Reserved]
20. Mixtures with hydrogen peroxide, water and acid(s).
21. With diluent type A, with or without water.
22. With ≥36% diluent type A by mass, and in addition ethylbenzene.
23. With ≥19% diluent type A by mass, and in addition methyl isobutyl ketone.
24. Diluent type B with boiling point >100 C.
25. No “Corrosive” subsidiary risk label is required for concentrations below 56%.
26. Available oxygen must be ≤7.6%.
27. Formulations derived from distillation of peroxyacetic acid originating from peroxyacetic acid in a concentration of not more than 41% with water, total active oxygen less than or equal to 9.5% (peroxyacetic acid plus hydrogen peroxide).
28. For the purposes of this section, the names “Peroxyacetic acid” and “Peracetic acid” are synonymous.
29. Not subject to the requirements of this subchapter for Division 5.2.
30. Diluent type B with boiling point >130°C (266°F).
31. Available oxygen ≤6.7%.

(d) *****

Table to Paragraph (d): Maximum Quantity per Packaging/Package

* * * * *

(g) * * *

Table to Paragraph (g) —Organic Peroxide Portable Tank Table
UN No. Hazardous material Minimum test pressure (bar) Minimum shell thickness (mm-reference steel) See . . . Bottom opening requirements See . . . Pressure-relief requirements See . . . Filling limits Control temperature Emergency temperature
3109 ORGANIC PEROXIDE, TYPE F, LIQUID
tert-Butyl hydroperoxide, not more than 72% with water.
*Provided that steps have been taken to achieve the safety equivalence of 65% tert-Butyl hydroperoxide and 35% water.
4 §178.274(d)(2) §178.275(d)(3) §178.275(g)(1) Not more than 90% at 59°F (15°C)
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
Note: 1. “Corrosive” subsidiary risk placard is required.

* * * * *

§173.301b Additional general requirements for shipment of UN pressure receptacles.

* * * * *

(c) * * *

(1) When the use of a valve is prescribed, the valve must conform to the requirements in ISO 10297:2014(E) and ISO 10297:2014/Amd 1:2017 (IBR, see §171.7 of this subchapter). Quick release cylinder valves for specification and type testing must conform to the requirements in ISO 17871:2015(E) (IBR, see §171.7 of this subchapter). Until December 31, 2022, the manufacture of a valve conforming to the requirements in ISO 10297:2014(E) is authorized. Until December 31, 2020, the manufacture of a valve conforming to the requirements in ISO 10297:2006(E) (IBR, see §171.7 of this subchapter) was authorized. Until December 31, 2008, the manufacture of a valve conforming to the requirements in ISO 10297:1999(E) (IBR, see §171.7 of this subchapter) was authorized.

(2) * * *

(ii) By equipping the UN pressure receptacle with a valve cap conforming to the requirements in ISO 11117:2008(E) and Technical Corrigendum 1 (IBR, see §171.7 of this subchapter). Until December 31, 2014, the manufacture of a valve cap conforming to the requirements in ISO 11117:1998(E) (IBR, see §171.7 of this subchapter) was authorized. The cap must have vent-holes of sufficient cross-sectional area to evacuate the gas if leakage occurs at the valve;

(iii) By protecting the valves by shrouds or guards conforming to the requirements in ISO 11117:2008(E) and Technical Corrigendum 1 (IBR; see §171.7 of this subchapter). Until December 31, 2014, the manufacture of a shroud or guard conforming to the requirements in ISO 11117:1998(E) (IBR, see §171.7 of this subchapter) was authorized. For metal hydride storage systems, by protecting the valves in accordance with the requirements in ISO 16111:2008(E) (IBR; see §171.7 of this subchapter).

(iv) By using valves designed and constructed with sufficient inherent strength to withstand damage in accordance with Annex B of ISO 10297:2014(E)/Amd. 1: 2017;

* * * * *

(d) Non-refillable UN pressure receptacles. (1) When the use of a valve is prescribed, the valve must conform to the requirements in ISO 11118:2015(E), (IBR, see §171.7 of this subchapter). Manufacture of valves to ISO 13340:2001(E) is authorized until December 31, 2020;

* * * * *

(f) Hydrogen bearing gases. A steel UN pressure receptacle bearing an ‘‘H’’ mark must be used for hydrogen bearing gases or other embrittling gases that have the potential of causing hydrogen embrittlement.

* * * * *

§173.302c Additional requirements for the shipment of adsorbed gases in UN pressure receptacles.

* * * * *

(k) The filling procedure must be in accordance with Annex A of ISO 11513 (IBR, see §171.7 of this subchapter).

* * * * *

§173.311 Metal hydride storage systems.

The following packing instruction is applicable to transportable UN Metal hydride storage systems (UN3468) with pressure receptacles not exceeding 150 liters (40 gallons) in water capacity and having a maximum developed pressure not exceeding 25 MPa. Metal hydride storage systems must be designed, constructed, initially inspected and tested in accordance with ISO 16111 (IBR, see §171.7 of this subchapter) as authorized under §178.71(m) of this subchapter. Steel pressure receptacles or composite pressure receptacles with steel liners must be marked in accordance with §173.301b(f) of this part which specifies that a steel UN pressure receptacle bearing an “H” mark must be used for hydrogen bearing gases or other gases that may cause hydrogen embrittlement. Requalification intervals must be no more than every five years as specified in §180.207 of this subchapter in accordance with the requalification procedures prescribed in ISO 16111.

§175.10 Exceptions for passengers, crewmembers, and air operators.

(a) This subchapter does not apply to the following hazardous materials when carried by aircraft passengers or crewmembers provided the requirements of §§171.15 and 171.16 (see paragraph (c) of this section) and the requirements of this section are met:

* * * * *

(14) Battery powered heat-producing devices (e.g., battery-operated equipment such as diving lamps and soldering equipment) as checked or carry-on baggage and with the approval of the operator of the aircraft. The heating element, the battery, or other component (e.g., fuse) must be isolated to prevent unintentional activation during transport. Any battery that is removed must be carried in accordance with the provisions for spare batteries in paragraph (a)(18) of this section.

* * * * *

(15) * * *

(v) * * *

(A) Securely attached to the wheelchair or mobility aid;

* * * * *

(vi) * * *

(A) Securely attached to the wheelchair or mobility aid; or

* * * * *

(17) * * *

(ii) * * *

(C) The battery must be securely attached to the mobility aid; and

* * * * *

(18) Except as provided in §173.21 of this subchapter, portable electronic devices (e.g., watches, calculating machines, cameras, cellular phones, laptop and notebook computers, camcorders, medical devices, etc.) containing dry cells or dry batteries (including lithium cells or batteries) and spare dry cells or batteries for these devices, when carried by passengers or crew members for personal use. Portable electronic devices powered by lithium batteries may be carried in either checked or carry-on baggage. When carried in checked baggage, portable electronic devices powered by lithium batteries must be completely switched off (not in sleep or hibernation mode) and protected to prevent unintentional activation or damage. Spare lithium batteries must be carried in carry-on baggage only. Each installed or spare lithium battery must be of a type proven to meet the requirements of each test in the UN Manual of Tests and Criteria, Part III, Sub-section 38.3, and each spare lithium battery must be individually protected so as to prevent short circuits (e.g., by placement in original retail packaging, by otherwise insulating terminals by taping over exposed terminals, or placing each battery in a separate plastic bag or protective pouch). In addition, each installed or spare lithium battery:

* * * * *

(26) Baggage equipped with lithium battery(ies) must be carried as carry-on baggage unless the battery(ies) is removed from the baggage. Removed battery(ies) must be carried in accordance with the provision for spare batteries prescribed in paragraph (a)(18) of this section. The provisions of this paragraph do not apply to baggage equipped with lithium batteries not exceeding:

* * * * *

§175.33 Shipping paper and information to the pilot-in-command.

(a) * * *

(13) * * *

(iii) For UN3480, UN3481, UN3090, and UN3091 prepared in accordance with §173.185(c), except those prepared in accordance with §173.185(c)(4)(vi), are not required to appear on the information to the pilot-in-command.

* * * * *

§178.37 Specification 3AA and 3AAX seamless steel cylinders.

* * * * *

(j) Flattening test. A flattening test must be performed on one cylinder taken at random out of each lot of 200 or less, by placing the cylinder between wedge shaped knife edges having a 60° included angle, rounded to ½-inch radius. The longitudinal axis of the cylinder must be at a 90-degree angle to knife edges during the test. For lots of 30 or less, flattening tests are authorized to be made on a ring at least 8 inches long cut from each cylinder and subjected to the same heat treatment as the finished cylinder. Cylinders may be subjected to a bend test in lieu of the flattening test. Two bend test specimens must be taken in accordance with ISO 9809–1 or ASTM E 290 (IBR, see §171.7 of this subchapter), and must be subjected to the bend test specified therein.

* * * * *

§178.71 Specifications for UN pressure receptacles.

* * * * *

(f) * * *

(4) ISO 21172-1:2015(E) Gas cylinders—Welded steel pressure drums up to 3,000 litres capacity for the transport of gases—Design and construction—Part 1: Capacities up to 1,000 litres (IBR, see §171.7 of this subchapter). Irrespective of section 6.3.3.4 of this standard, welded steel gas pressure drums with dished ends convex to pressure may be used for the transport of corrosive substances provided all applicable additional requirements are met.

(g) Design and construction requirements for UN refillable seamless steel cylinders. In addition to the general requirements of this section, UN refillable seamless steel cylinders must conform to the following ISO standards, as applicable:

(1) ISO 9809-1:2010 Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 1: Quenched and tempered steel cylinders with tensile strength less than 1100 MPa. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-1:1999 (IBR, see §171.7 of this subchapter) is authorized.

(2) ISO 9809-2: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 2: Quenched and tempered steel cylinders with tensile strength greater than or equal to 1100 MPa. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-2:2000 (IBR, see §171.7 of this subchapter) is authorized.

(3) ISO 9809-3: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-3:2000 (IBR, see §171.7 of this subchapter) is authorized.

(4) ISO 9809-4:2014(E) (IBR, see §171.7 of this subchapter).

* * * * *

(i) Design and construction requirements for UN non-refillable metal cylinders. In addition to the general requirements of this section, UN non-refillable metal cylinders must conform to ISO 11118:2015(E) Gas cylinders—Non-refillable metallic gas cylinders—Specification and test methods (IBR, see §171.7 of this subchapter). Until December 31, 2020, cylinders conforming to ISO 11118:1999(E) Gas cylinders—Non-refillable metallic gas cylinders—Specification and test methods (IBR, see §171.7 of this subchapter) are authorized.

* * * * *

(k) * * *

(1) * * *

(i) ISO 9809-1:2010 Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 1: Quenched and tempered steel cylinders with tensile strength less than 1100 MPa. Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-1:1999 (IBR, see §171.7 of this subchapter) is authorized.

(ii) ISO 9809-3: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders. Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-3:2000 (IBR, see §171.7 of this subchapter) is authorized.

* * * * *

(m) Design and construction requirements for UN metal hydride storage systems. In addition to the general requirements of this section, metal hydride storage systems must conform to the following ISO standards, as applicable: ISO 16111: Transportable gas storage devices—Hydrogen absorbed in reversible metal hydride (IBR, see §171.7 of this subchapter).

(n) Design and construction requirements for UN cylinders for the transportation of adsorbed gases. In addition to the general requirements of this section, UN cylinders for the transportation of adsorbed gases must conform to the following ISO standards, as applicable: ISO 11513:2011, Gas cylinders—Refillable welded steel cylinders containing materials for sub-atmospheric gas packaging (excluding acetylene)—Design, construction, testing, use and periodic inspection, or ISO 9809-1:2010: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 1: Quenched and tempered steel cylinders with tensile strength less than 1100 MPa. (IBR, see §171.7 of this subchapter.)

* * * * *

§178.75 Specifications for MEGCs.

* * * * *

(d) * * *

(3) Each pressure receptacle of a MEGC must be of the same design type, seamless steel, or composite, and constructed and tested according to one of the following ISO standards, as appropriate:

(i) ISO 9809-1: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 1: Quenched and tempered steel cylinders with tensile strength less than 1100 MPa. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-1:1999 (IBR, see §171.7 of this subchapter) is authorized;

(ii) ISO 9809-2: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 2: Quenched and tempered steel cylinders with tensile strength greater than or equal to 1100 MPa. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-2:2000 (IBR, see §171.7 of this subchapter) is authorized;

(iii) ISO 9809-3: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-3:2000 (IBR, see §171.7 of this subchapter) is authorized; or

* * * * *

§178.609 Test requirements for packagings for infectious substances.

* * * * *

(d) * * *

(2) Where the samples are in the shape of a drum, three samples must be dropped, one in each of the following orientations:

(i) Diagonally on the top chime, with the center of gravity directly above the point of impact;

(ii) Diagonally on the base chime; and

(iii) Flat on the side.

* * * * *

§178.706 Standards for rigid plastic IBCs.

* * * * *

(c) * * *

(3) No used material other than production residues or regrind from the same manufacturing process may be used in the manufacture of rigid plastic IBCs.

* * * * *

§178.707 Standards for composite IBCs.

* * * * *

(c) * * *

(3) * * *

(iii) No used material other than production residues or regrind from the same manufacturing process may be used in the manufacture of inner receptacles.

* * * * *

§180.207 Requirements for requalification of UN pressure receptacles.

* * * * *

(d) * * *

(3) Dissolved acetylene UN cylinders: Each dissolved acetylene cylinder must be requalified in accordance with ISO 10462:2013(E) (IBR, see §171.7 of this subchapter). A cylinder previously requalified in accordance with the second edition of ISO 10462(E) up until December 31, 2018, may continue to be used until the next required requalification. The porous mass and the shell must be requalified no sooner than 3 years, 6 months, from the date of manufacture. Thereafter, subsequent requalifications of the porous mass and shell must be performed at least once every ten years.

* * * * *

(5) UN cylinders for adsorbed gases: Each UN cylinder for adsorbed gases must be inspected and tested in accordance with §173.302c and ISO 11513:2011 (IBR, see §171.7 of this subchapter).

* * * * *

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Most Recent Highlights In Environmental

Effluent limitations: FAQs for direct dischargers of industrial wastewater
2026-04-16T05:00:00Z

Effluent limitations: FAQs for direct dischargers of industrial wastewater

Facilities across the country conduct industrial activities that generate wastewater containing pollutants and then release it directly into nearby surface waters, such as streams, rivers, or lakes. However, before any industrial wastewater can be discharged from a site, the facility must obtain a National Pollutant Discharge Elimination System (NPDES) permit.

The Environmental Protection Agency (EPA) uses effluent limitations as the primary method to regulate direct discharges of industrial wastewater into waters of the United States. These restrictions are incorporated into NPDES permits.

Meeting effluent limitations is the key to compliance with NPDES permits. But like other environmental regulations, these standards can get complex quickly without a solid foundation of understanding. We’ve compiled common FAQs to help you become fluent in effluent limitations.

What’s effluent?

There’s no specific statutory or regulatory definition of “effluent.” Thankfully, a 1997 document from EPA entitled Terms of Environment: Glossary, Abbreviations, and Acronyms, Revised December 1997 (EPA 175-B-97-001) provides clarity, defining effluent as “wastewater — treated or untreated — that flows out of a treatment plant, sewer, or industrial outfall.”

What’s the difference between effluent guidelines and limitations?

There are subtle but important distinctions between these two terms.

Effluent guidelines (also known as effluent limitations guidelines and standards or ELGs) are the national industrial wastewater discharge standards established by EPA for all facilities in an industrial category.

The federal agency develops effluent guidelines based on the performance of the best available technology that’s economically achievable for an industry. Notably, effluent guidelines are technology-based; they’re not based on risk or impacts to receiving waters (i.e., water quality-based).

Federal effluent guidelines (40 CFR Subchapter N) for direct dischargers of industrial wastewater are implemented through the NPDES permitting program.

Effluent limitations are any restrictions imposed “on quantities, discharge rates, and concentrations of pollutants” from industrial wastewater discharges (122.2). Simply put, effluent limitations are the specific numeric and non-numeric requirements developed for facilities to comply with the effluent guidelines. Unlike effluent guidelines, effluent limitations may be both technology- and water quality-based.

Most states issue NPDES permits, except for the District of Columbia, Massachusetts, New Hampshire, and New Mexico, where EPA serves as the permitting authority. The permit writer develops effluent limitations for NPDES permits and issues them to facilities. The permit may be general (covering multiple facilities with similar operations and discharges) or individual (customized with site-specific conditions).

What’s the bottom line? Effluent guidelines aren’t directly enforceable permit conditions, whereas effluent limitations are.

What are the types of effluent limitations?

Two categories of effluent limitations may appear in NPDES permits:

  • Technology-based effluent limitations (TBELs), and
  • Water quality-based effluent limitations (WQBELs).

TBELs are based on available treatment technologies and require facilities to meet a minimum level of treatment of pollutants in wastewater discharges.

WQBELs apply only when TBELs aren’t enough to achieve water quality standards. States develop total maximum daily loads (TMDLs). A TMDL is the maximum amount of a pollutant that can be discharged into a waterbody while still meeting the water quality standards. Specific portions of the TMDL are then allotted to permitted facilities (called wasteload allocation). Facilities can’t release more than their allocated amounts.

Any applicable wasteload allocations are incorporated into a facility’s NPDES permit.

Do facilities have to use specific control technologies?

Although EPA’s effluent guidelines are based on the use of a specific control technology, facilities aren’t required to install the same technology system. As long as they comply with the standards, facilities may implement other treatment technologies.

Key to remember: Understanding effluent limitations is key to complying with industrial wastewater discharge permits.

EPA proposes major changes to coal combustion residuals rules
2026-04-16T05:00:00Z

EPA proposes major changes to coal combustion residuals rules

The Environmental Protection Agency (EPA) published a proposed rule on April 13, 2026, to revise the existing regulations governing the disposal of coal combustion residuals (CCR) in landfills and surface impoundments as well as the beneficial use of CCR.

Who’s impacted?

The proposed rule affects coal-fired electric utilities and independent power producers subject to the CCR disposal and beneficial use regulations at 40 CFR Part 257.

What are the changes?

Significant changes the EPA proposes include:

  • Adding an option for facilities to certify the closure of legacy CCR surface impoundments by CCR removal that were closed before November 8, 2024, under regulatory oversight;
  • Expanding the eligibility criteria for facilities to defer CCR closure requirements until site-specific determinations are made for legacy surface impoundments that were closed before November 8, 2024, under regulatory oversight;
  • Exempting CCR dewatering structures (used to dewater CCR waste for the disposal of CCR elsewhere) from federal CCR regulations (Part 257);
  • Rescinding all CCR management unit (CCRMU) requirements or revising the existing CCRMU regulations;
  • Allowing permit authorities to make site-specific determinations regarding certain requirements during permitting for CCR units complying with federal CCR groundwater monitoring, corrective action, and closure requirements under a federal or an approved-state CCR permit; and
  • Revising the beneficial use requirements by:
    • Removing the environmental demonstration requirement for non-roadway use of more than 12,400 tons of unencapsulated CCR; and
    • Excluding these beneficial uses from federal CCR regulations (Part 257):
      • CCR used in cement manufacturing at cement kilns,
      • Flue gas desulfurization (FGD) gypsum used in agriculture, and
      • FGD gypsum used in wallboard.

Key to remember: EPA plans to make significant amendments to the coal combustion residuals requirements.

What to know about the EPA’s proposed manifest sunset rule
2026-04-14T05:00:00Z

What to know about the EPA’s proposed manifest sunset rule

The U.S. Environmental Protection Agency (EPA) is taking another major step toward modernizing hazardous waste tracking. The Agency’s proposed “manifest sunset rule” would officially phase out paper hazardous waste manifests and require the exclusive use of the e-Manifest system. For employers, especially those generating or managing hazardous waste, it’s a fundamental shift in how waste shipments are documented, tracked, and audited.

Since 2018, EPA’s e-Manifest system has been available as a digital alternative to paper manifests. Over the years, the agency has added requirements pushing the industry toward adoption, including mandatory registration and electronic data submission. But despite those efforts, many companies have continued to rely on paper manifests, either out of habit, convenience, or because parts of their waste chain weren’t ready to go digital. EPA even states in the proposed rule that less than one percent of all e-manifest users have completely switched to digital manifest. The proposed sunset rule is designed to close that gap. Once finalized, it would set a firm deadline (24 months) after which paper manifests would no longer be allowed.

Why EPA wants to eliminate paper manifests

EPA’s reasoning is pretty straightforward. Paper manifests are slower, easier to lose, and more prone to errors. They rely on manual handling and delayed processing, which can create gaps in tracking and compliance. A fully electronic system, on the other hand, allows for real-time visibility, standardized data entry, and faster correction of mistakes. It also gives regulators a clearer, more immediate picture of what’s happening across the entire waste life cycle.

Addressing one of the biggest digital barriers: signatures

One overlooked part of the proposed rule is how EPA is trying to solve one of the biggest barriers to going fully digital, which is signatures in the field. Anyone who has dealt with manifests knows that the weak point is often the hand-off between the generator and the transporter, especially when drivers don’t have system access or reliable connectivity. To address that, EPA is proposing new functionality that would allow users to sign manifests using quick response (QR) codes or even short message service (SMS). In practice, this could mean a driver scans a QR code or receives a text prompt, then completes the signature process directly from their phone. So, no login or full system access needed. EPA is also exploring the ability to use SMS and QR-based tools to make updates to manifest data without needing full system permissions. That’s a big deal operationally, because it removes one of the most common bottlenecks in needing a registered user at a specific site to make even minor corrections.

Operational challenges companies should expect

With that said, moving to a fully digital system still comes with potential issues. It requires coordination across your entire operation. Generators, transporters, and disposal facilities all have to be aligned and capable of using the system effectively. If one party in that chain struggles, it can create delays or compliance issues for everyone involved. There’s also an upfront investment to consider. Companies may need to upgrade internal systems, ensure reliable connectivity, and train employees in new work processes. For organizations with multiple sites or field operations, which can take some planning. But over time, many of those burdens are expected to decrease. Electronic signatures, reusable templates, and centralized record-keeping can significantly reduce administrative work.

One of the biggest shifts employers will notice is the level of visibility. With paper manifests, there’s often a lag between shipment and final documentation. In a digital system, that lag disappears. Information becomes available almost immediately, and regulators have access to the same data. That means errors or discrepancies are easier to find and harder to ignore.

The good news is that companies don’t have to wait for the final rule to start preparing. Taking a close look at your current manifest process is a good first step. If paper is still a major part of your workflow, that’s a clear signal that changes are coming. Making sure your e-Manifest account is fully set up and that employees understand how to use it, will go a long way in avoiding future disruptions.

Keys to remember: The EPA’s proposed Paper Manifest Sunset Rule would set a firm date to phase out paper hazardous waste manifests and require that all covered shipments be tracked through the agency’s electronic e‑Manifest system, in which the Agency says will improve hazardous‑waste tracking and transparency while reducing administrative burden and saving regulated entities roughly $28.5 million per year.

How incinerators are permitted: A look at the regulatory framework and EPA’s new streamlining proposal
2026-04-13T05:00:00Z

How incinerators are permitted: A look at the regulatory framework and EPA’s new streamlining proposal

Incinerators in the United States operate under a complex permitting framework designed to protect air quality, public health, and the environment. Under the Clean Air Act (CAA), facilities that burn waste must meet strict emission standards, maintain operating controls, and follow extensive monitoring and reporting rules. These requirements ensure that incineration, while a valuable tool for waste management, wildfire mitigation, and disaster recovery, remains safe and consistent with federal air quality objectives. Against this backdrop, the U.S. Environmental Protection Agency (EPA) recently proposed a rule to streamline permitting for specific types of incinerators used in wildfire prevention and disaster cleanup, a move that could reduce delays for state and local governments.

The regulatory basis for incinerator permitting

Most incinerators fall under Section 129 of the Clean Air Act, which mandates EPA to establish performance standards and emission guidelines for categories of solid waste combustion units. These standards govern pollutants such as particulate matter, carbon monoxide, sulfur dioxide, nitrogen oxides, lead, cadmium, mercury, hydrogen chloride, and dioxins/furans. Operators must also conduct emissions testing, maintain continuous monitoring equipment, track operational parameters, and submit regular compliance reports.

Permitting generally occurs through Title V operating permits, which consolidate all applicable air quality requirements into a single enforceable document. A Title V permit typically requires annual certifications, detailed recordkeeping, periodic emissions tests, and reporting of deviations. While the Title V program does not impose new standards, it ensures that incinerators comply with all existing federal and state air quality rules.

Different categories of incinerators such as Large Municipal Waste Combustors (LMWC), Small Municipal Waste Combustors (SMWC), Commercial and Industrial Solid Waste Incinerators (CISWI), and Other Solid Waste Incinerators (OSWI) have distinct requirements. These subcategories reflect variations in unit size, waste composition, and operational design, and each has its own subpart under EPA’s air quality regulations.

Air curtain incinerators: A special case

Air Curtain Incinerators (ACIs), which burn wood waste, yard debris, and clean lumber, occupy a niche segment of the permitting landscape. They use a mechanized “curtain” of air to increase combustion efficiency and reduce particulate emissions compared to open burning. However, their regulatory treatment has historically been inconsistent.

Because ACIs fit partly within several existing subparts, operators often face confusion about which monitoring, opacity limits, and reporting duties apply. Overlap across four regulatory categories can create delays, particularly during emergencies when ACIs are deployed to remove vegetative fuels that increase wildfire risk or to process debris after storms.

EPA’s emergent focus on streamlining

In March 2026, EPA announced a proposal to consolidate the regulatory requirements for ACIs used solely to burn wood derived materials into a single subpart under Section 129. The proposal would also allow these ACIs to operate without a Title V permit unless located at a facility that otherwise requires one.

EPA stated that the change would “cut red tape” and provide clarity for state, local, and Tribal governments, allowing them to respond more effectively to natural disasters and conduct wildfire mitigation activities without unnecessary administrative delays. The agency emphasized that unprocessed debris contributes to poor air and water quality and poses safety risks, particularly in post disaster environments.

Context: Broader federal actions on disaster related incineration

The proposal follows earlier federal steps to ease temporary use of incinerators during emergencies. In 2025, EPA issued an interim final rule permitting CISWI units to burn nonhazardous disaster debris for up to eight weeks without prior EPA approval, a provision intended to accelerate cleanup after hurricanes, wildfires, and floods. These units must still operate their pollution control equipment, and extensions beyond eight weeks require EPA authorization.

Such measures reflect the increasing volume of debris associated with severe weather events and the need for rapid, environmentally sound disposal mechanisms. The current proposal for ACIs builds on these efforts by targeting the specific regulatory bottlenecks associated with vegetative and wood waste disposal.

Looking ahead

EPA’s streamlined permitting proposal does not alter emissions standards but rather clarifies and simplifies administrative pathways. If finalized, it may make ACIs more accessible during periods of heightened wildfire risk and in the critical early stages of disaster recovery.

Key to remember: At its core, the permitting system for incinerators aims to balance environmental protection with operational flexibility. The new proposal underscores EPA’s recognition that, in emergency contexts, speed matters but so does environmental stewardship.

EPA delays TSCA Section 8(a)(7) PFAS reporting timeline again
2026-04-13T05:00:00Z

EPA delays TSCA Section 8(a)(7) PFAS reporting timeline again

On April 13, 2026, the Environmental Protection Agency (EPA) published a final rule that further delays the submission period for the one-time report required of manufacturers on per- and polyfluoroalkyl substances (PFAS) by the PFAS Reporting and Recordkeeping Rule (PFAS Reporting Rule).

This final rule pushes the starting submission period to either 60 days after the effective date of a future final rule updating the PFAS Reporting Rule or January 31, 2027, whichever is earlier.

Who’s impacted?

Established under Toxic Substances Control Act (TSCA) Section 8(a)(7), the PFAS Reporting Rule (40 CFR Part 705) requires any business that manufactured (including imported) any PFAS or PFAS-containing article between 2011 and 2022 to report. Covered manufacturers and importers must submit information on:

  • Chemical identity, uses, and volumes made and processed;
  • Byproducts;
  • Environmental and health effects;
  • Worker exposure; and
  • Disposal.

What’s the new timeline?

The opening submission period was moved from April 13, 2026, to either 60 days after the effective date of a future final PFAS Reporting Rule or January 31, 2027, whichever is earlier.

Most manufacturers have 6 months to submit the report. Small manufacturers reporting only as importers of PFAS-containing articles have 1 year.

TSCA Section 8(a)(7) PFAS Reporting Rule submission period
Start dateEnd date
Most manufacturers60 days from effective date of final PFAS Reporting Rule or January 31, 2027 (whichever is earlier)6 months from start date or July 31, 2027 (whichever is earlier)
Small manufacturers reporting solely as PFAS article importers60 days from effective date of final PFAS Reporting Rule or January 31, 2027 (whichever is earlier)1 year from start date or January 31, 2028 (whichever is earlier)

Why the delay?

In November 2025, the agency proposed updates to the PFAS Reporting Rule. EPA has delayed the reporting period to give the agency time to issue a final rule (expected later this year).

Key to remember: EPA has delayed the starting submission deadline for the TSCA Section 8(a)(7) PFAS Reporting Rule from April 2026 to no later than January 2027.

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Most Recent Highlights In Transportation

EPA amends specific oil and gas emission standards
2026-04-10T05:00:00Z

EPA amends specific oil and gas emission standards

On April 9, 2026, the Environmental Protection Agency (EPA) published a final rule that makes technical changes to the emission standards established in March 2024 (2024 Final Rule) for crude oil and natural gas facilities. This rule (2026 Final Rule) amends the requirements for:

  • Temporary flaring of associated gas, and
  • Vent gas net heating value (NHV) monitoring provisions for flares and enclosed combustion devices (ECDs).

Who’s impacted?

The 2026 Final Rule affects new and existing oil and gas facilities. Specifically, it applies to the regulations for the Crude Oil and Natural Gas source category, including the:

  • New Source Performance Standards at 40 CFR 60 Subpart OOOOb, and
  • Emission guidelines at 60 Subpart OOOOc.

These emission standards are commonly referred to as OOOOb/c.

What are the changes?

The 2026 Final Rule implements technical changes to the temporary flaring and vent gas NHV monitoring requirements set by the 2024 Final Rule.

Temporary flaring

The rule extends the baseline time limit for temporary flaring of associated gas at well sites in certain situations (like conducting repairs or maintenance) from 24 to 72 hours. Owners and operators must stop temporary flaring as soon as the situation is resolved or the temporary flaring limit is reached (whichever happens first).

It also grants allowances beyond the 72-hour limit if exigent circumstances occur (such as severe weather that prevents safe access to a well site to address an emergency or maintenance issue) and there’s a need to extend duration for repairs, maintenance, or safety issues. Owners and operators must keep records of exigent circumstances and include the information in their annual reports.

NHV monitoring

For new and existing sources, the 2026 Final Rule exempts all flare types (unassisted and assisted) and ECDs from monitoring due to high NHV content, except when inert gases are added to the process streams or for other scenarios that decrease the NHV content of the inlet stream gas. In these cases, EPA requires NHV monitoring via continuous monitoring or the alternative performance test (sampling demonstration) option for all flares and ECDs.

Other significant changes include:

  • Replacing the general exemption from NHV monitoring for associated gas for any control device used at well site affected facilities with NHV monitoring requirements,
  • Granting operational pauses during weekends and holidays for the consecutive 14-day sampling demonstration requirements (limiting it to no more than 3 operating days from the previous sampling day), and
  • Permitting less than 1-hour sampling times for twice daily samples where low or intermittent flow makes it infeasible (as long as owners and operators report the sampling time used and the reason for the reduced time).

The 2026 Final Rule takes effect on June 8, 2026.

Key to remember: EPA’s technical changes to the emission standards for oil and gas facilities apply to temporary flaring provisions and vent gas NHV monitoring requirements.

EHS Monthly Round Up - March 2026

EHS Monthly Round Up - March 2026

In this March 2026 roundup video, we'll review the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.

OSHA released an updated Job Safety and Health poster. Employers can use either the revised version or the older one, but the poster must be displayed in a conspicuous place where workers can easily see it.

OSHA recently removed a link from its Data topic webpage that displayed a list of “high-penalty cases” at or over $40,000 since 2015. The agency says it discontinued and removed it in December. The data is frozen and archived elsewhere.

OSHA published two new resources as part of its newly launched Safety Champions Program. The fact sheet provides an overview of how the program works, eligibility criteria, and key benefits. The step-by-step guide helps businesses navigate the core elements of OSHA’s Recommended Practices for Safety and Health Programs.

Several forces are nudging OSHA to address a number of workplace hazards and high-hazard industries. This comes from other agencies, safety organizations, watchdogs, legislative proposals, and persistent injury/fatality data. Among the hazards are combustible dust; first aid; personal protective equipment; and workplace violence. How all this translates into new regulations, guidance, programmed inspections, or other initiatives remains to be seen.

Turning to environmental news, EPA issued a proposed rule to require waste handlers to use electronic manifests to track all RCRA hazardous waste shipments. Stakeholders have until May 4 to comment on the proposal.

On March 10, EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to related standards.

And finally, EPA temporarily extended coverage under the 2021 Multi-Sector General Permit for industrial stormwater discharges until the agency issues a new general permit. The permit expired February 28 and remains in effect for facilities previously covered. EPA won’t take enforcement action against new facilities for unpermitted stormwater discharges if the facilities meet specific conditions.

Thanks for tuning in to the monthly news roundup. We’ll see you next month!

EPA releases draft list of drinking water contaminants for possible regulation
2026-04-07T05:00:00Z

EPA releases draft list of drinking water contaminants for possible regulation

The Environmental Protection Agency (EPA) published the draft Sixth Contaminant Candidate List (CCL 6) for the next group of contaminants to be considered for regulation under the Safe Drinking Water Act (SDWA). The agency’s proposed list designates microplastics and pharmaceuticals as priority contaminant groups for the first time.

What’s on the list?

The proposed CCL 6 contains:

  • 4 chemical groups, including:
    • Microplastics,
    • Pharmaceuticals,
    • Per- and polyfluoroalkyl substances (PFAS), and
    • Disinfection byproducts.
  • 75 chemicals; and
  • 9 microbes.

EPA may regulate the listed contaminants in the future.

What does the CCL do?

The drinking water CCL is the first part of the process to regulate contaminants in public water systems. The list identifies unregulated contaminants known or anticipated to be present in drinking water that pose the greatest health risk. It helps EPA prioritize which contaminants to evaluate for potential regulation.

The SDWA requires EPA to make regulatory determinations (i.e., whether to develop rules for a contaminant) for at least five contaminants listed on the CCL every 5 years. When the agency determines a contaminant needs to be regulated, it begins the rulemaking process to develop a National Primary Drinking Water Regulation (NPDWR) for the contaminant. The NPDWRs apply to public water systems.

How can I participate?

EPA will receive public comments on the CCL 6 through June 5, 2026. You can send comments to EPA via regulations.gov or by mail. Make sure your submission includes the Docket ID No. EPA-HQ-OW-2022-0946.

Key to remember: The draft list of the next round of drinking water contaminants to be considered for regulation adds priority groups for microplastics and pharmaceuticals.

EPA delivers 2026–2027 renewable fuel volumes
2026-04-03T05:00:00Z

EPA delivers 2026–2027 renewable fuel volumes

On April 1, 2026, the Environmental Protection Agency (EPA) published the “Set 2” Rule, establishing the Renewable Fuel Standard (RFS) program’s 2026 and 2027 renewable fuel volumes and associated percentage standards for:

  • Cellulosic biofuel,
  • Biomass-based diesel (BBD),
  • Advanced biofuel, and
  • Total renewable fuel.

The final rule also implements other significant changes.

Who’s impacted?

The “Set 2” Rule affects:

  • Transportation fuel (i.e., gasoline and diesel) refiners, blenders, marketers, distributors, importers, and exporters; and
  • Renewable fuel producers and importers.

The volume and percentage requirements apply to obligated parties, which include transportation fuel refiners and importers.

What are the changes?

The final rule sets the renewable fuel volume requirements and associated percentage standards for 2026 and 2027. Volume requirements are measured in billion Renewable Identification Numbers (RINs). One RIN represents 1 gallon of ethanol-equivalent renewable fuel.

Renewable fuel categoryVolume requirements (in billion RINs)Percentage standards
2026202720262027
Cellulosic biofuel1.361.430.79%0.84%
BBD9.079.205.24%5.37%
Advanced biofuel11.1011.326.42%6.61%
Total renewable fuel26.8127.0215.50%15.78%

The “Set 2” Rule also:

  • Reallocates 70 percent of the exempted Renewable Volume Obligations (RVOs) for 2023–2025 to 2026 and 2027 (which are reflected in the above table’s volume requirements),
  • Partially waives the 2025 cellulosic biofuel volume requirement from 1.38 billion RINs to 1.21 billion RINs and adjusts the related percentage standard from 0.81 percent to 0.71 percent, and
  • Removes renewable electricity as a qualifying renewable fuel under the RFS program.

RFS program refresher

The RFS program requires transportation fuel sold in the United States to contain a minimum volume of renewable fuels. EPA sets the renewable fuel volume targets for each of the four renewable fuel categories.

To comply, obligated parties must:

  • Calculate their RVOs for each renewable fuel category, and
  • Obtain and retire enough RINs to meet their RVOs.

Regulations also apply to fuel blenders, marketers, and exporters.

Small refiners may petition EPA for a small refinery exemption (SRE), which allows refineries to produce gasoline and diesel without having to meet the RVOs required by the RFS program. EPA grants SREs annually, and they cover one specific compliance year.

Key to remember: EPA’s final “Set 2” rule establishes the renewable fuel volumes and percentage standards for 2026 and 2027 and drives other changes to the RFS program.

EPA releases final NESHAP for chemical manufacturing area sources
2026-04-02T05:00:00Z

EPA releases final NESHAP for chemical manufacturing area sources

The Environmental Protection Agency (EPA) published a final rule on April 1, 2026, amending the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Chemical Manufacturing Area Sources (CMAS). The NESHAP controls hazardous air pollutant (HAP) emissions from facilities that manufacture a range of chemicals and products, such as inorganic chemicals, plastics, and synthetic rubber.

Who’s impacted?

The final rule applies to nine area source categories in the chemical manufacturing sector that are regulated by the CMAS NESHAP (40 CFR 63 Subpart VVVVVV).

What are the changes?

EPA’s final rule:

  • Establishes leak detection and repair requirements for equipment leaks and heat exchange systems in organic HAP service,
  • Adds detectable emissions monitoring standards for pressure vessels in organic HAP service and emission management practice standards for pressure relief devices (PRDs) in organic HAP service,
  • Prohibits closed vent systems in organic HAP service from bypassing an air pollution control device (APCD), and
  • Requires recurring performance testing of non-flare APCDs to demonstrate compliance with process vent and storage tank provisions.

The final rule also mandates electronic reporting for notifications of compliance status (NOCs), performance test reports, and periodic reports. Facilities must submit these reports through the Compliance and Emissions Data Reporting Interface (CEDRI) on EPA’s Central Data Exchange.

What didn’t change?

Significantly, the final rule doesn’t add previously proposed regulations for area sources that use ethylene oxide (EtO) to produce materials described by code 325 of the North American Industry Classification System (NAICS).

EPA states that it intends to address the regulation of EtO from area sources and major sources in one final action.

What are the compliance timelines?

Existing facilities must comply with the amendments by April 1, 2029.

New facilities (those that begin construction or reconstruction after January 22, 2025) have to comply with the changes by April 1, 2026, or upon startup, whichever is later.

Additionally, facilities must start electronically submitting:

  • Performance tests by June 1, 2026;
  • NOCs by August 31, 2026; and
  • Periodic reports by April 1, 2029.

Key to remember: EPA’s final HAP emissions rule for chemical manufacturing area sources adds new requirements for certain processing equipment and systems.

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EPCRA inventory reports: A case study in federal, state, and local collaboration
2026-03-31T05:00:00Z

EPCRA inventory reports: A case study in federal, state, and local collaboration

Environmental regulations require many facilities to report annual inventories of the hazardous chemicals they use or store. Have you ever considered the impact that this information has beyond regulatory compliance? Reporting facilities, whether they realize it or not, serve an essential role in local emergency response planning.

The Environmental Protection Agency’s (EPA’s) Hazardous Chemical Inventory Reporting program under the Emergency Planning and Community Right-to-Know Act (EPCRA) offers a prime example of how collaboration among the federal, state, local, and facility levels supports safer communities.

What’s EPCRA's inventory reporting program?

The Occupational Safety and Health Administration (OSHA) requires facilities to keep Safety Data Sheets (SDSs) for any hazardous chemical used or stored in the workplace. Facilities that use or store the chemicals on-site at or above certain thresholds at any one time are subject to EPCRA’s Hazardous Chemical Inventory Reporting program. Regulated facilities must report information about the hazardous chemicals to the:

  • State Emergency Response Commission (SERC),
  • Local Emergency Planning Committee (LEPC), and
  • Local fire department.

What’s reported?

EPA’s EPCRA inventory program consists of two reporting requirements under Sections 311 and 312 of EPCRA.

SDSs/lists

Section 311 of EPCRA requires facilities to submit the SDSs for or a list of the hazardous chemicals used or stored on-site at or above the reporting thresholds to the SERC, LEPC, and local fire department.

SDSs usually include comprehensive information, such as:

  • The composition of ingredients,
  • Physical and health hazard information, and
  • First aid and firefighting measures.

If a facility opts to list the chemicals, it must group them by hazard categories and include each chemical’s name and any hazardous components as identified by the SDS. This is generally a one-time submission for each hazardous chemical. However, if a facility submits an SDS for a hazardous chemical and later discovers significant new information about it, the facility has to send an updated SDS to the SERC, LEPC, and local fire department.

Annual inventories

Under Section 312 of EPCRA, facilities must also submit an annual inventory (known as the Tier II inventory report) of the hazardous chemicals used or stored on-site at or above the reporting thresholds to the SERC, LEPC, and local fire department by March 1.

Facilities should check state regulations to confirm Tier II reporting thresholds, as they may be more stringent.

The Tier II inventory report requires information on the covered hazardous chemicals used or stored at the facility during the previous calendar year, including:

  • The locations of the chemicals,
  • The amounts of the chemicals, and
  • The potential hazards of the chemicals.

How do inventories support emergency planning?

Inventory reports provide information that’s vital to effective emergency response planning. Specifically, the inventories tell state and local officials about where hazardous chemical releases may occur and the risks that such releases may pose. Equipped with an accurate view of these hazards, officials can build and maintain effective emergency response plans for their communities.

Each participant in the emergency planning effort plays a distinct role:

  • Reporting facilities provide the SERCs, LEPCs, and local fire departments with the information they need to build effective response plans, such as the types of chemicals on-site and their quantities, locations, and possible hazards.
  • SERCs designate local emergency planning districts and appoint and supervise LEPCs. They also establish the inventory reporting procedures, review local emergency response plans, and process information requests from the public.
  • LEPCs use inventory reports to develop and update emergency response plans that address each community’s unique risks.
  • Local fire departments use the inventory reports to understand the potential chemical-related risks they may encounter at specific facilities. By knowing where the chemicals are and the potential hazards they pose, fire departments can improve personnel training and identify the most appropriate ways to respond to chemical emergencies.

Ultimately, reporting facilities aren’t just meeting a compliance requirement; they’re also supporting safer communities.

Key point: EPCRA’s hazardous chemical inventory requirements provide an example of effective collaboration between EPA, state and local officials, and facilities to prepare communities for chemical emergencies.

2026-03-27T05:00:00Z

Expert Insights: Four commonly overlooked categories in TRI reporting

Toxics Release Inventory (TRI) reporting can be tricky, even for seasoned EHS teams. Many facilities meet all the requirements but still miss chemicals that should be reported. Most oversights fall into four key categories. Here’s what they are and why they get missed, along with a few simple examples that show up in routine operations.

Newly added or updated TRI chemicals

The TRI list changes more often than many people realize. The Environmental Protection Agency (EPA) regularly updates it and recently added new per- and polyfluoroalkyl substances (PFAS) and even a full diisononyl phthalate (DINP) chemical category. When facilities don’t review these updates each year, they may keep using materials that now contain reportable chemicals without realizing it. For example, PFAS were expanded for Reporting Years 2024 and 2025, and the DINP category was added in 2023. These changes mean that everyday items like coatings, lubricants, and flexible plastics can suddenly trigger TRI thresholds.

“Otherwise used” chemicals

Not every reportable chemical is manufactured or processed. Many are simply “otherwise used,” including solvents, degreasers, cleaners, and maintenance chemicals. Facilities often overlook these because they aren’t part of the product mix, but they can add up fast. Even common shop chemicals, when used across a year, can exceed the 10,000-pound threshold and require reporting.

Coincidentally manufactured byproducts

Some chemicals are created unintentionally during normal operations. Ammonia may form during baking or heating steps, nitrates often appear in wastewater treatment, and metal compounds can be generated during welding, machining, or corrosion. These substances count as “manufactured” under TRI even if they weren’t intentionally manufactured. Examples like ammonia, nitrates, metal compounds, and diesel byproducts such as naphthalene and polycyclic aromatic compounds are regularly overlooked in TRI reporting because they’re easy to underestimate.

Impurities or additives in mixtures

Many reportable chemicals hide inside mixtures, oils, coatings, lubricants, and chemical blends. If a facility focuses only on the main ingredients, it may miss the smaller additive or impurity that’s actually subject to TRI reporting. These overlooked components can push a facility over a reporting threshold, even when the product is used in small amounts.

TRI oversights usually occur not because facilities ignore the rules but because chemicals show up in unexpected forms. Keeping an eye on updates, tracking cleaners and maintenance chemicals, monitoring byproducts, and checking mixtures closely can prevent the most common reporting mistakes.

The essential role of local governments in environmental regulation
2026-03-25T05:00:00Z

The essential role of local governments in environmental regulation

Counties and municipalities play a major role in protecting air, water, and land resources across the United States. Although federal and state agencies establish the overarching environmental framework, thousands of local agencies conduct the day to day permitting, inspections, and enforcement needed to make those rules work.

Local governments obtain regulatory authority largely through delegation. Federal environmental laws such as the Clean Air Act, Clean Water Act, and Resource Conservation and Recovery Act (RCRA) allow the Environmental Protection Agency (EPA) to authorize state agencies, which may then rely on local entities to administer components of these programs. In many states, local districts, counties, or municipalities operate significant environmental programs directly under state authority.

Common local level programs

A strong example of local involvement can be seen in air quality management. The National Association of Clean Air Agencies (NACAA) reports that 117 local air agencies participate in implementing federal and state clean air programs, highlighting how implementation frequently happens at the local level.

EPA’s AirNow directory lists numerous local air quality agencies across the country; Examples include air pollution control districts in California (such as the Sacramento Metropolitan Air Quality Management District, the San Francisco Bay Area Air Quality Management District, and the South Coast Air Quality Management District) as well as local air programs in Maricopa County, Arizona; Jacksonville, Florida; and Omaha, Nebraska. These districts conduct inspections, issue permits, investigate complaints, and maintain air monitoring networks, all of which support state and federal clean air requirements.

Local authority is also central to solid waste management, where many states rely heavily on counties and municipalities to manage planning, facilities, and enforcement. For instance, Washington State requires local governments to develop comprehensive solid and hazardous waste management plans that guide all waste handling and recycling programs within each county or city. These plans determine facility needs, outline reduction and recycling strategies, and shape local ordinances designed to meet state goals.

Additional examples appear across the country. Maryland’s Montgomery County, California’s Alameda County, and the District of Columbia all implement ambitious local waste diversion plans that supplement or exceed state requirements, demonstrating how counties and cities directly shape waste reduction and recycling policy. Likewise, South Carolina places most solid waste management responsibility on county governments, which must develop local plans, designate recycling coordinators, and report progress toward statewide goals.

Why is local involvement critical?

Local environmental regulatory authority matters because conditions vary widely across the nation. Counties and municipalities better understand their own industries, land uses, and growth patterns, allowing them to respond quickly to complaints, target outreach effectively, and adopt ordinances that go beyond state or federal minimums when necessary. Their proximity to communities makes local agencies essential partners in achieving environmental compliance and advancing public health protections.

As federal and state programs evolve, the role of local agencies continues to expand. Air quality districts, solid waste authorities, and local environmental health departments all demonstrate how counties and municipalities contribute directly to national environmental objectives.

Key to remember: With thousands of local agencies responsible for on the ground regulatory tasks, the strength and responsiveness of the United States’ environmental protection system depend heavily on the active engagement of local governments.

Toxics Release Inventory: Are you ready to report?
2026-03-24T05:00:00Z

Toxics Release Inventory: Are you ready to report?

Every year at the beginning of July, industrial facilities across the nation can breathe a collective sigh of relief — their annual inventories of toxic chemicals are complete! To ensure that your facility can be part of that celebration (and avoid a chaotic rush to meet the deadline), now’s the perfect time to start preparing for the Toxics Release Inventory (TRI).

The Environmental Protection Agency’s (EPA’s) TRI program requires industrial facilities to report waste management data on certain toxic chemicals they manufacture, process, and use by July 1 each year. Is your facility ready to report? Here’s an overview of the TRI program to help you answer this question.

Who’s covered by TRI reporting?

Generally, TRI reporting applies if the facility:

  • Is in a covered industry sector (40 CFR 372.23);
  • Employs 10 or more full-time-equivalent employees; and
  • Manufactures, processes, or otherwise uses a covered chemical or chemical category (372.65) in quantities above the threshold levels (372.25, .27, and .28) in a given year.

TRI tip: The TRI reporting year (RY) reflects the calendar year covered by the report, not the year in which you submit the report. For example, TRI reports for RY 2025 are due by July 1, 2026.

What’s covered by TRI reporting?

Facilities must submit the TRI Form R (or the streamlined Form A Certification Statement if eligible) for each TRI-listed chemical manufactured, processed, or used during the previous calendar year. The data covers chemical waste management activities (including releases to the environment) and any actions taken to reduce or prevent chemical waste.

Facilities usually report for each chemical:

  • The quantities of releases (routine and accidental),
  • Any releases caused by catastrophic or other one-time events,
  • The maximum amount on-site during the year, and
  • The amount contained in wastes managed on-site or transferred off-site.

What’s new for RY 2025?

The TRI reports for RY 2025 contain three differences from previous years:

  • The de minimis level for anthracene was lowered from 1.0 percent to 0.1 percent. Anthracene’s Chemical Abstracts Service Registry Number (CASRN) is 120-12-7.
  • More activity sub-use codes were added to the sub-use codes for “processing” and “otherwise use” activities.
  • Nine per- and polyfluoroalkyl substances (PFAS) were added to the TRI chemical list:
EPA registry nameCASRN
6:2 fluorotelomer sulfonate acid27619-97-2
6:2 fluorotelomer sulfonate ammonium salt59587-39-2
6:2 fluorotelomer sulfonate anion425670-75-3
6:2 fluorotelomer sulfonate potassium salt59587-38-1
6:2 fluorotelomer sulfonate sodium salt27619-94-9
Acetic acid, [(.gamma.-.omega.-perfluoro-C8-10-alkyl)thio] derivs., Bu esters3030471-22-5
Ammonium perfluorodecanoate3108-42-7
Perfluoro-3-methoxypropanoic acid377-73-1
Sodium perfluorodecanoate3830-45-3

How are TRI reports submitted?

Facilities must submit TRI reports electronically to the TRI-MEweb application on EPA’s Central Data Exchange (CDX). Even if a facility uses its own software to prepare TRI forms, it must upload and submit the forms to TRI-MEweb.

TRI tip: To complete the submission process on TRI-MEweb, you need to assign one user the Preparer role and another user the Certifying Official role. Ensure both users have added TRI-MEweb to their CDX user accounts.

TRI reports must be submitted to both EPA and the state. If your facility’s state participates in the TRI Data Exchange (TDX), TRI-MEweb will automatically send your report to the state. If your facility’s state doesn’t participate, you must send a hard copy of the report to the TRI state contact.

TRI tip: Use EPA’s “TRI Data Exchange” webpage to determine whether your facility’s state participates in TDX. As of March 2026, all 50 states participate in TDX. The District of Columbia doesn’t participate.

More TRI tips

Keep these things in mind when preparing your TRI reports:

  • You must submit a Form R (or Form A if eligible) for each TRI-listed chemical your facility manufactured, processed, or otherwise used above the threshold quantity.
  • TRI data is publicized. If a chemical’s identity needs to be protected, you have to submit substantiation forms to claim the chemical identity as a trade secret. EPA must approve the claims. Further, for each chemical with a trade secret claim, you have to mail hard copies of the substantiation forms and the corresponding Form Rs (or Form As if eligible) to EPA and the state.
  • EPA’s online GuideME platform offers comprehensive guidance for TRI reporting, including reporting forms and instructions, the TRI chemical list, and Q&As.
  • Contact the state environmental agency directly to confirm the submission method. EPA’s “TRI State Contacts” webpage contains state contact information.
  • Register your facility on CDX or ensure your facility’s CDX account is updated as soon as possible to avoid delays caused by technical issues.

Start preparing for TRI reporting now to give your facility plenty of time to gather data, complete the forms, and respond to unexpected issues that could arise. That way, your facility can breathe easily throughout the whole reporting season.

Key to remember: The submission deadline for TRI reporting is July 1, 2026. Make sure your facility is ready to report.

Final rule adds EtO emission limits to polyether polyol production
2026-03-19T05:00:00Z

Final rule adds EtO emission limits to polyether polyol production

The Environmental Protection Agency (EPA) finalized major changes to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyether Polyols (PEPO) Production (PEPO NESHAP).

Who’s impacted?

The final rule applies to facilities that produce polyether polyols and are subject to the regulations at 40 CFR 63 Subpart PPP.

What are the changes?

EPA’s final rule establishes ethylene oxide (EtO) standards, updates maximum achievable control technology (MACT) requirements, and revises other provisions for the PEPO NESHAP.

EtO standards

The final rule adds EtO emission standards for:

  • Equipment leaks,
  • Heat exchange systems,
  • Process vents,
  • Storage vessels, and
  • Wastewater.

The standards set emission limits and add requirements for monitoring and leak repairs.

MACT standards

Further, the final rule:

  • Requires heat exchange systems to use the more sensitive Modified El Paso Method (also known as the Air Stripping Method) for quarterly monitoring and a leak definition of 6.2 parts per million by volume of total strippable hydrocarbon concentration (as methane) in the stripping gas,
  • Lowers the MACT control thresholds for batch process vents and storage vessels,
  • Updates the requirements for internal floating roof storage vessels,
  • Lowers the threshold for equipment leaks for valves in gas/vapor service or light liquid service, and
  • Requires transfer operations with loading operations that exceed a certain threshold to use a vapor balance system or reduce emissions.

Other standards

EPA’s final rule also:

  • Requires 5-year performance testing for process vent control devices;
  • Revises flare monitoring and operational requirements to ensure they meet the MACT standards at all times when controlling hazardous air pollutant (HAP) emissions;
  • Adds new monitoring requirements for pressure vessels to verify that no detectable emissions exist;
  • Clarifies that any bypass of a pollution control device for closed vent systems is a violation;
  • Aligns the requirements for surge control vessels and bottoms receivers with the process vent standards;
  • Adds butylene oxide to the definition of “epoxide” and the HAPs list;
  • Expands “affected source” to cover specific post-reaction processes; and
  • Finalizes work practice standards for maintenance vents and equipment openings, storage vessel degassing, and routine storage vessel maintenance.

However, EPA didn’t finalize the 2024 proposed rule’s addition of a fenceline monitoring program for EtO or its changes to the continuous process vent standard.

What’s the compliance timeline?

Facilities subject to the PEPO NESHAP must comply with the changes by March 18, 2029, or upon startup, whichever is later.

Key to remember: EPA’s final rule for polyether polyol emissions makes significant changes, such as establishing EtO limits and revising MACT standards.

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Key questions in industrial stormwater compliance
2026-03-16T05:00:00Z

Key questions in industrial stormwater compliance

Industrial stormwater compliance can feel complex for facilities balancing operations, employees, and shifting permit requirements. Many questions center on the federal general permit, pollution prevention plan expectations, monitoring, and what to do in everyday situations where stormwater risks arise. The following sections summarize core topics and practical concerns.

What is the current status of the federal 2021 Multi-Sector General Permit (MSGP)?

EPA issued the current MSGP in 2021, and it remains in effect beyond its February 28, 2026 expiration until EPA finalizes the proposed 2026 MSGP. Because the proposed 2026 permit is still under review, the 2021 MSGP continues to govern covered facilities.

Why has the proposed 2026 MSGP not taken effect?

EPA released the proposed 2026 MSGP in December 2024. Public comments, including an extended comment period ending May 19, 2025, must be reviewed before finalizing the permit. Since the existing MSGP remains valid until replaced, the 2021 permit stays in force while EPA completes its process.

What is a Stormwater Pollution Prevention Plan (SWPPP)?

A SWPPP outlines how a facility prevents pollutants from reaching stormwater. It identifies pollutant sources, control measures, inspection routines, monitoring steps, and staff training. A SWPPP must be written before submitting a Notice of Intent (NOI) for permit coverage and updated when operations or stormwater risks change.

What are the requirements for authorized state stormwater permits?

Most states issue their own industrial stormwater permits modeled on the federal MSGP. These permits typically require:

  • Preparation and maintenance of a SWPPP;
  • Inspections and monitoring (such as benchmark, effluent, or visual monitoring);
  • Corrective actions when control measures fail; and
  • Reporting through state online systems.

States may add requirements based on local conditions. When EPA updates the MSGP, states often revise their permits to align with new federal standards.

Who needs coverage under the MSGP?

Industrial facilities that discharge stormwater to waters of the United States generally need permit coverage unless they qualify for a no‑exposure exclusion. The federal MSGP applies in areas where EPA, not the state, holds National Pollutant Discharge Elimination System (NPDES) authority.

How does a facility obtain coverage?

To obtain coverage, a facility must:

  • Prepare and implement a SWPPP;
  • Put pollution controls in place, such as good housekeeping and spill prevention;
  • Identify sector specific requirements based on the permit; and
  • Submit a Notice of Intent through EPA’s online system.

The proposed 2026 MSGP includes updated forms and appendices, but current requirements remain based on the 2021 version until a new permit is published.

What monitoring is required?

Under the 2021 MSGP, required monitoring may include:

  • Quarterly visual assessments,
  • Benchmark monitoring in designated years, and
  • Effluent limitations monitoring for specific regulated discharges.

The proposed 2026 MSGP would expand per- and polyfluoroalkyl substances (PFAS) sampling, increase benchmark monitoring frequency, and add requirements for impaired waters. These changes remain pending.

What happens if benchmark thresholds are exceeded?

A benchmark exceedance requires the facility to investigate causes, improve control measures, and document actions in the SWPPP. The proposed 2026 MSGP would formalize additional implementation measures and reporting steps, but these wouldn’t apply until the new permit takes effect.

What about common real world compliance scenarios?

Industrial stormwater issues often arise from everyday activities. Consider these examples:

Employees’ vehicles leaking oil in parking lots

Leaks from employee vehicles can contaminate stormwater. While the MSGP does not regulate personal vehicles directly, the facility is responsible for any pollutants that enter stormwater from its property. Good housekeeping practices include absorbent stations, spill kits, drip pans, and designated parking areas with routine inspection.

Nonroutine outdoor maintenance

Temporary outdoor activities such as conducting maintenance, unloading equipment, or staging materials, can introduce pollutants. The SWPPP should address nonroutine tasks by requiring temporary controls like tarps, containment pads, or scheduling activities during dry weather. Documentation of these activities is also part of good recordkeeping.

Outdoor waste storage or scrap piles

These materials should be covered or sheltered, kept away from storm drains, and inspected frequently. If runoff contacts industrial materials, the discharge becomes regulated and must be managed under the permit.

These scenarios reinforce the need for strong housekeeping practices, staff training, and prompt corrective actions.

What documentation must facilities keep?

Facilities must maintain monitoring records, inspection logs, SWPPP updates, and corrective action reports. EPA may request these documents at any time. Appendices in the proposed 2026 MSGP preview updated forms, but the 2021 requirements remain in place for now.

What should facilities do while waiting for the 2026 MSGP?

Facilities should continue full compliance with the 2021 MSGP, track regulatory updates, and prepare for more frequent monitoring and PFAS sampling likely included in the 2026 permit. Reviewing proposed changes now helps facilities plan needed SWPPP updates in advance.

Key to remember: Industrial facilities covered under the 2021 MSGP or a state equivalent must continue following that permit until EPA issues a new federal MSGP. Staying informed, maintaining strong housekeeping, and keeping SWPPP documentation current remain the most effective strategies for compliance.

Toxics Release Inventory: Are you ready to report?
2026-03-13T05:00:00Z

Toxics Release Inventory: Are you ready to report?

Every year at the beginning of July, industrial facilities across the nation can breathe a collective sigh of relief — their annual inventories of toxic chemicals are complete! To ensure that your facility can be part of that celebration (and avoid a chaotic rush to meet the deadline), now’s the perfect time to start preparing for the Toxics Release Inventory (TRI).

The Environmental Protection Agency’s (EPA’s) TRI program requires industrial facilities to report waste management data on certain toxic chemicals they manufacture, process, and use by July 1 each year. Is your facility ready to report? Here’s an overview of the TRI program to help you answer this question.

Who’s covered by TRI reporting?

Generally, TRI reporting applies if the facility:

  • Is in a covered industry sector (40 CFR 372.23);
  • Employs 10 or more full-time-equivalent employees; and
  • Manufactures, processes, or otherwise uses a covered chemical or chemical category (372.65) in quantities above the threshold levels (372.25, .27, and .28) in a given year.

TRI tip: The TRI reporting year (RY) reflects the calendar year covered by the report, not the year in which you submit the report. For example, TRI reports for RY 2025 are due by July 1, 2026.

What’s covered by TRI reporting?

Facilities must submit the TRI Form R (or the streamlined Form A Certification Statement if eligible) for each TRI-listed chemical manufactured, processed, or used during the previous calendar year. The data covers chemical waste management activities (including releases to the environment) and any actions taken to reduce or prevent chemical waste.

Facilities usually report for each chemical:

  • The quantities of releases (routine and accidental),
  • Any releases caused by catastrophic or other one-time events,
  • The maximum amount on-site during the year, and
  • The amount contained in wastes managed on-site or transferred off-site.

What’s new for RY 2025?

The TRI reports for RY 2025 contain three differences from previous years:

  • The de minimis level for anthracene was lowered from 1.0 percent to 0.1 percent. Anthracene’s Chemical Abstracts Service Registry Number (CASRN) is 120-12-7.
  • More activity sub-use codes were added to the sub-use codes for “processing” and “otherwise use” activities.
  • Nine per- and polyfluoroalkyl substances (PFAS) were added to the TRI chemical list:

EPA registry nameCASRN
6:2 fluorotelomer sulfonate acid27619-97-2
6:2 fluorotelomer sulfonate ammonium salt59587-39-2
6:2 fluorotelomer sulfonate anion425670-75-3
6:2 fluorotelomer sulfonate potassium salt59587-38-1
6:2 fluorotelomer sulfonate sodium salt27619-94-9
Acetic acid, [(.gamma.-.omega.-perfluoro-C8-10-alkyl)thio] derivs., Bu esters3030471-22-5
Ammonium perfluorodecanoate3108-42-7
Perfluoro-3-methoxypropanoic acid377-73-1
Sodium perfluorodecanoate3830-45-3

How are TRI reports submitted?

Facilities must submit TRI reports electronically to the TRI-MEweb application on EPA’s Central Data Exchange (CDX). Even if a facility uses its own software to prepare TRI forms, it must upload and submit the forms to TRI-MEweb.

TRI tip: To complete the submission process on TRI-MEweb, you need to assign one user the Preparer role and another user the Certifying Official role. Ensure both users have added TRI-MEweb to their CDX user accounts.

TRI reports must be submitted to both EPA and the state. If your facility’s state participates in the TRI Data Exchange (TDX), TRI-MEweb will automatically send your report to the state. If your facility’s state doesn’t participate, you must send a hard copy of the report to the TRI state contact.

TRI tip: Use EPA’s “TRI Data Exchange” webpage to determine whether your facility’s state participates in TDX. As of March 2026, all 50 states participate in TDX. The District of Columbia doesn’t participate.

More TRI tips

Keep these things in mind when preparing your TRI reports:

  • You must submit a Form R (or Form A if eligible) for each TRI-listed chemical your facility manufactured, processed, or otherwise used above the threshold quantity.
  • TRI data is publicized. If a chemical’s identity needs to be protected, you have to submit substantiation forms to claim the chemical identity as a trade secret. EPA must approve the claims. Further, for each chemical with a trade secret claim, you have to mail hard copies of the substantiation forms and the corresponding Form R (or Form A if eligible) to EPA and the state.
  • EPA’s online GuideME platform offers comprehensive guidance for TRI reporting, including reporting forms and instructions, the TRI chemical list, and Q&As.
  • Contact the state environmental agency directly to confirm the submission method. EPA’s “TRI State Contacts” webpage contains state contact information.
  • Register your facility on CDX or ensure your facility’s CDX account is updated as soon as possible to avoid delays caused by technical issues.

Start preparing for TRI reporting now to give your facility plenty of time to gather data, complete the forms, and respond to unexpected issues that could arise. That way, your facility can breathe easily throughout the whole reporting season.

Key to remember: The submission deadline for TRI reporting is July 1, 2026. Make sure your facility is ready to report.

EPA finalizes emission standards for large municipal waste combustors
2026-03-12T05:00:00Z

EPA finalizes emission standards for large municipal waste combustors

On March 10, 2026, the Environmental Protection Agency (EPA) finalized emission regulations for large municipal waste combustors (LMWCs). The final rule revises nearly all emission limits for new and existing LMWCs.

Who’s impacted?

The final rule applies to LMWCs that combust more than 250 tons per day of municipal solid waste and are covered by the:

  • New Source Performance Standards (NSPS) for new LMWCs, or
  • Emission Guidelines (EGs) for existing LMWCs.

EPA established new subparts for the amendments at 40 CFR Part 60, including:

  • Subpart VVVV for the NSPS, and
  • Subpart WWWW for the EGs.

What are the changes?

Generally, stricter emission limits apply. For all LMWCs (new and existing), the rule revises the emission limits for:

  • Cadmium,
  • Hydrogen chloride,
  • Lead,
  • Mercury,
  • Particulate matter,
  • Polychlorinated dibenzodioxins and dibenzofurans, and
  • Sulfur dioxide.

For all new LMWCs, the final rule revises the emission limits for carbon monoxide (CO) and nitrogen oxides (NOx). The final rule also amends the CO and NOx limits for all existing LMWCs, except for the CO limits for two subcategories of combustors and the NOx limits for two subcategories of combustors for new municipal solid waste incinerators.

Other major changes include:

  • Removing certain exclusions and exemptions for startups, shutdowns, and malfunctions (requiring LMWCs to meet emission standards at all times);
  • Removing the NOx emissions averaging compliance alternative for existing LMWCs;
  • Amending recordkeeping and reporting requirements; and
  • Eliminating Title V operating air permit requirements for qualifying air curtain incinerators that burn only wood waste, yard waste, and clean lumber.

What’s the compliance timeline?

When EPA updates EGs, states must revise their State Implementation Plans (SIPs) to incorporate the changes. States have to submit revised SIPs by March 10, 2027. Once EPA approves the SIP, facilities with existing LMWCs must meet the new standards either within 3 years of the SIP’s approval date or by March 10, 2031, whichever is earlier.

New LMWCs must comply with the amended NSPS by September 10, 2026, or upon startup, whichever is later.

Key to remember: EPA finalized stronger emission limits for new and existing large municipal waste combustors and made other changes to the standards.

EHS Monthly Round Up - February 2026

EHS Monthly Round Up - February 2026

In this Februrary 2026 roundup video, we'll discuss the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what happened over the past month.

Fatal work injuries fell 4 percent in 2024, largely due to a decline in workplace drug- and alcohol-related overdoses. According to the Bureau of Labor Statistics, overdose fatalities fell from 512 in 2023 to 410 in 2024. Across all types of workplace incidents, there were 5,070 fatal work injuries in 2024, compared to 5,283 in 2023. Transportation incidents continue to be the most frequent type of fatal event, accounting for over 38 percent of all occupational fatalities in 2024.

OSHA is fast-tracking a proposal to remove the 2036 obligation to upgrade fall protection systems on fixed ladders that extend over 24 feet. This follows an industry petition from major chemical and petroleum industry groups, which argue the provision is unjustified, costly, and not supported by the rulemaking record. OSHA frames the upcoming proposed action as deregulatory, allowing employers to update fixed ladders at the end of their service lives. We’ll provide updates as more information becomes available.

As OSHA leans into “deregulatory” actions, lawmakers are moving to pressure the agency to issue “regulatory” rulemaking to protect American workers. The latest legislative wave of bills aims to fill regulatory gaps, tackle emerging hazards, expand OSHA authority, and raise penalties. Topics addressed by these bills include musculoskeletal disorders, heat stress, infectious diseases, wildfire smoke, and workplace violence.

In a recently issued letter of interpretation, OSHA states that a burn injury caused by a personal lithium-ion battery fire is work related if it occurs in the workplace during assigned working hours. The letter details an incident where an employee was burned when their rechargeable lithium-ion batteries for e-cigarettes sparked a fire after coming into contact with a key used for work.

A new report from the Department of Labor Office of Inspector General concludes that OSHA struggles to meet its mission, particularly in high-risk industries like healthcare, construction, and manufacturing. Several pages point to OSHA’s difficulties in effectively enforcing annual injury and illness reporting requirements, reaching the nation’s high-risk worksites for inspection, and addressing workplace violence by regulatory or other action.

Turning to environmental news, EPA extended the deadlines for Facility Evaluation Reports and related requirements for coal combustion residuals facilities. In most instances, the deadlines have been moved one or two years out.

And finally, EPA announced a final rule eliminating the 2009 Endangerment Finding and related greenhouse gas emission requirements for on-highway vehicles and vehicle engines. When the final rule takes effect, manufacturers and importers of new motor vehicles and motor vehicle engines will no longer have to measure, report, certify, or comply with federal greenhouse gas emission standards.

Thanks for tuning in to the monthly news roundup. We’ll see you next month!

2026-03-06T06:00:00Z

Colorado adds landfill methane emission regulation

Effective date: February 14, 2026

This applies to: Open and closed municipal solid waste landfills

Description of change: The Colorado Air Quality Control Commission added Regulation 31, which establishes new emission control and monitoring requirements for municipal solid waste landfills. Applicability is based on the landfill’s amount of waste it holds and methane emissions.

Significant changes implemented by Regulation 31 include:

  • Establishing a stricter emission control threshold than federal standards so that more landfills must install gas collection and control systems,
  • Mandating closed landfills with emission combustion devices to install biofilters when the devices are removed,
  • Expanding the methane monitoring requirements (allowing additional monitoring tools for identifying large emission sources) and allowing alternative monitoring technologies for periodic monitoring, and
  • Phasing in a ban on open flares to replace them with enclosed flares.

Related state info: Clean air operating permits state comparison

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Citations

Citations

Citations describe OSHA requirements allegedly violated, list any proposed penalties, and give a deadline for correcting the alleged hazards.

The compliance officer will give you a call approximately two weeks before you can expect the violations to be sent in the mail. OSHA sends citations of proposed penalties by certified mail. Employers are required to post a copy of each citation at or near the place a violation occurred, for three days or until the violation is abated, whichever is longer.

Instance-by-instance citations

It should be noted that OSHA can cite violations as instance-by-instance (IBI). An instance would relate to each machine, employee, location, entry, etc. that violates a standard or when instances of the violation could not be abated by a single method of abatement.

An April 17, 2024, OSHA enforcement memo, "Instance-by-Instance Citation Policy for Serious, Repeat, and Other-than-Serious Violations," says the agency may cite violations IBI when one or more of the factors below are met:

  • The violations are related to an incident that resulted in a fatality, catastrophe, or permanently disabling injury/illness;
  • The employer has a history of willful, repeat, or failure-to-abate violations;
  • The inspection revealed one or more willful, repeat, or failure-to-abate violation(s), or a significant number of serious violations; or
  • The inspection revealed widespread recordkeeping deficiencies (for which IBI recordkeeping citation items may be proposed).

Citations at multi-employer worksites

On multi-employer worksites, more than one employer may be citable for a hazardous condition that violates an OSHA standard. Under the agency’s Multi-Employer Citation Policy (CPL 02-00-124), OSHA will first determine whether each of the site employers is a creating, exposing, correcting, or controlling employer. If an employer falls into one of these categories, it has obligations with respect to OSHA requirements, and the agency will determine if the employer’s actions were sufficient to meet those obligations.

Top 25 cited OSHA standards and laws for general industry

Every year, OSHA compiles statistics on cited standards and laws. The following is preliminary information on the top ones during fiscal year 2025:

  1. Hazard Communication — 1910.1200
  2. Lockout/Tagout — 1910.147
  3. Respiratory Protection — 1910.134
  4. Powered Industrial Trucks — 1910.178
  5. Machine Guarding (General) — 1910.212
  6. Electrical Systems Design (General) — 1910.303
  7. Abatement Verification — 1903.19
  8. Personal Protective Equipment (General) — 1910.132
  9. Electrical (Wiring and Equipment) — 1910.305
  10. General Duty Clause — Section 5(a)(1) of Occupational Safety and Health Act
  11. Fatality and Severe Injury Reporting — 1910.39
  12. Exit Route Maintenance, Safeguards, and Operational Features — 1910.37
  13. Portable Fire Extinguishers — 1910.157
  14. Duty to Have Fall Protection and Falling Object Protection — 1910.28
  15. Respirable Crystalline Silica —1910.1053
  16. Walking-working Surfaces (General) — 1910.22
  17. Occupational Noise Exposure — 1910.95
  18. Mechanical Power Transmission Apparatus — 1910.219
  19. Medical Services and First Aid — 1910.151
  20. Electronic Submission of Injury/Illness Records — 1904.41
  21. Permit-required Confined Spaces — 1910.146
  22. Process Safety Management — 1910.119
  23. Bloodborne Pathogens — 1910.1030
  24. Abrasive Wheel Machinery — 1910.215
  25. Spray Finishing Using Flammable and Combustible Materials — 1910.107
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