Office of Hazardous Materials Safety: HazMat Shippers and Cylinder Requalifiers Top Two Priorities
In one of the first actions after the longest government shutdown in history, the new acting Associate Administrator for Hazardous Materials Safety issued a memo outlining the agency’s top inspection and enforcement priorities. The November 20th memo listed the first priority as “general hazardous materials shippers” and the second as “cylinder requalification facilities.”
Tym’s Advantage
Tym’s LLC was founded on supporting small to medium size businesses with regulatory assistance, training, and compliance solutions for these very two activities. We have seen, first hand, the challenges that businesses face navigating the complexity of the Hazardous Materials Regulations (HMR) in the face of historically lax and sometimes inconsistent oversight by the Office of Hazardous Materials Safety (OHMS).
Be Cautious
While we applaud the data-driven approach and focus on outreach, as proported in the memo, we take pause anytime the enforcement arm of an agency offers unsolicited assistance. When the only tool is a hammer, everything is treated like a nail.
We hope that this memo introduces a new era of enforcement that refocuses the agency to reward willful compliance. In the past, simple renewals and well-intended questions resulted in enforcement actions. We advise a “wait and see” approach.
Be Audit Ready
In any case, if you perform hydrostatic testing on cylinders or ship any type of Hazardous Materials, now is the time to get your regulatory house in order. Our training, processes, and compliance solutions have always focused on the very issues that are now the primary priority of the of the DOT.
Reach out today for a consultation:
Read More
Read the OHMS Inspection and Enforcement Priorities Memo here.
Tym’s submitted comments in 2024 regarding the development of “general investigative questions” that may be asked during the agency’s “outreach” program described in the memo:
The same year, Tym’s sent a letter to DOT PHMSA regarding administrative renewals that lead to unfair scrutiny. We hope the recent memo indicates a transition away from this practice: