PHMSA Amendment HM-219

By December 3, 2018 September 12th, 2019 Regulations, 49 CFR, Regulation Updates

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued another final rule on November 7th. Again, this rule making is the only way to amend or change Title 49 for Transportation in the Code of Federal Regulations. In this case, the docket number is HM–219. Its goal is to “to update, clarify, streamline, or provide relief for miscellaneous regulatory requirements”. It has an effective date of December 7, 2018. While the published rule is only 20 pages long there are many areas of revision. Below is a list of the items that jumped out at me while reading it. If you wish to read the full rule making, please visit

HM-219 Highlights:

  • Section 172.205 had changes to paragraph (j) which pertains to the Hazardous waste manifest. You are now allowed to use electronic signatures when completing EPA forms 8700-22 and 8700-22A.
  • Section 172.407 had revisions to paragraphs (c) and (f). Paragraph (c) now says “inner border approximately 5 mm inside and parallel to the edge”. It still says the inner border must be 2 mm wide and that the thinner line border labels can be used until the end of the year. Paragraph (f) has included some additional references. It now says, “a label conforming to specifications in the UN Recommendations, the ICAO Technical Instructions, the IMDG Code, or the Transport Canada TDG Regulations … may be used in place of a corresponding label that conforms to the requirements of this subpart.” Note, this does not include the poisonous by inhalation labels.
  • Section 172.519 had the same sort of changes as 172.407, but in regards to placards. Both paragraphs (c) and (f) have adjusted the wording. Paragraph (c) mentions the inner border on placards being approximately 12.5 mm inside and parallel to the edge and incorporates the ICAO, IMDG and TDG regulations. There is still a notation regarding poisonous by inhalation hazard placards.
  • 1172.604 paragraph (d) was modified and an emergency response telephone number is now not required for hazardous materials shipped excepted quantities.
  • 173.24a had adjustments to paragraphs (b)(1) and (3). Packages tested with a liquid material may now be filled with solid of the equivalent packing group. This is quite a game changer. Our packaging specialist, Mike Zendano, will have a blog dedicated to this soon. Stay tuned.
  • 173.150 which is the exceptions for flammable liquids reworked paragraph (g) on limited quantities of retail products containing ethyl alcohol. The units of measurement used now are the International System of Units more commonly known as metric. For example, rather than listing “16 fluid ounces” it now will have “0.47 liters (0.125 gallons)”.
  • 173.156 Exceptions for limited quantity and ORM-D in paragraph (b)(2)(iii) will now allow packages to be placed on pallets made of not just wood but also metal, plastic or composite materials.

There are other changes as well. Some apply to compressed gases and chemicals under pressure. Section 178 on Packaging Specifications also has multiple revisions. If you or your company have dealings in that section, there are four areas of change. The continuing qualification and maintenance of packagings in Section 180 didn’t escape the changes brought on by this amendment.

Take the time to get up to speed now. I expect more changes on the horizon and with new editions of IATA and IMDG already published, staying on top of the changes will be of utmost importance. If you have questions, reach out to our regulatory department through our helpdesk today.

Paula Reavis

Paula Reavis

Degrees: BS in Science Education, BA in Chemistry, MA in School Counseling Certification: National Certified Counselor Paula Reavis comes to us with a teaching background and several years of experience in Hazard Communications. She is knowledgeable in HazCom2012, WHMIS (old/new), 49 CFR, IATA, IMDG and TDG. She started with the company in 2014, and is currently the Trainer for the US. She is active in several associations including NACD, IHMM and SCHC where she served as chair of the Membership and Awards Committee. She is based in St. Louis, Missouri.