IHMM Today is an online publication of the Institute of Hazardous Materials Management® (IHMM®).

Other than content specifically provided by IHMM, articles contained in IHMM Today are compiled from

independent sources and do not necessarily reflect the opinions of IHMM.

Inside IHMM

IHMM launched its “Open to Work” online COLLABORATION community exclusively for IHMM certificants looking to connect, share resumes, and discover job opportunities together in a supportive environment.

You can find this community after logging into COLLABORATION here: https://community.ihmm.org/home

Sean Grady, CHMM – Environmental Transformation Podcast

Sponsored Content

Environmental Protection Agency Issues its Spring 2025 Regulatory Agenda – Read more here

Department of Transportation Issues Spring 2025 Regulatory  Agenda – Read more here

Department of Labor Issues its Spring 2025 Regulatory Agenda – Read more here

IHMM Issues Memorandum – EPA – Updated Definition of Waters of the United States

On November 17, 2025, the U.S. Environmental Protection Agency and the Department of the Army (“the agencies”) announced the signing of a proposed rule to revise the definition of “waters of the United States.” This proposal implements the Supreme Court’s decision in Sackett v. EPA. The proposed rule will play a key role in EPA’s Powering the Great American Comeback initiative by protecting water resources, strengthening cooperative federalism, and supporting American industry, energy producers, the technology sector, farmers, ranchers, developers, businesses, and landowners.

In developing the proposed rule, EPA and the Army reviewed and considered the extensive feedback and recommendations the agencies received from States, Tribes, local governments, and stakeholders throughout consultations and the pre-proposal recommendations docket and listening sessions.

Read more here.

PFAS Reporting Rule Update for CHMMs & CHMPs

Deadline for Comment:  December 15, 2025

Federal Register

Risk Matrix for CHMM/CMHP and the Proposed Rule

EPA has proposed significant amendments to its PFAS Reporting and Recordkeeping Rule under TSCA § 8(a)(7). The revisions introduce new exemptions—including a 0.1% de minimis threshold, PFAS in imported articles, non-commercial byproducts and impurities, non-isolated intermediates, and PFAS used solely for R&D. These changes are designed to reduce regulatory burden while preserving critical PFAS reporting requirements for 2011–2022.

For IHMM certificants, the rule remains directly relevant. CHMMs and CHMPs are often responsible for identifying PFAS in materials, auditing historical data, classifying wastes, documenting releases, and ensuring TSCA-compliant reporting. EPA continues to require “known or reasonably ascertainable” information, meaning organizations must search existing records—including SDSs, waste manifests, analytical reports, and supply-chain documentation—to determine whether PFAS were manufactured, used, disposed of, or released. See the Risk Matrix above.

The proposal reinforces core CHMM and CHMP competencies across hazardous materials identification, recordkeeping, waste management, and environmental assessment. IHMM certificants remain essential to organizational compliance and risk reduction as PFAS regulations continue to evolve.

IHMM is preparing comments to submit in response to this proposed rulemaking, and we will provide updates, tools, and training to support our certificants’ leadership in PFAS management.

IHMM – Workplace EHS Coalition Supports OSHA/NIOSH Funding

IHMM, and the Workplace EHS Coalition of which IHMM is a part, is writing to Congressional appropriators in support of funding OSHA and NIOSH, following up on our call for funding those organizations first made last May. With the shutdown over and Congress now back, we have prepared a letter to key House and Senate appropriations subcommittee leaders supporting robust funding levels for OSHA and NIOSH in any full-year FY2026 spending deal.

Fall 2025 Letter to Congress OSHA/NIOSH

The Workplace EHS Coalition (formerly known as the Intersociety Forum) is a coalition of organizations, including ASSP, dedicated to safeguarding worker safety and health and promoting the fact that safety practices create a strategic advantage that powers enduring business success while fostering innovation and protecting workers.

Despite advancements, workplace injury and fatality rates remain stagnant. By adopting proactive, risk-based safety strategies, businesses can unlock greater productivity, reduce costs, and strengthen their global competitiveness. The Workplace EHS Coalition urges today’s business leaders and policymakers to prioritize occupational EHS as a foundation of economic competitiveness. Adopting this approach will position the U.S. as a global leader in safety, innovation and workforce well-being, enabling workers and businesses to thrive.

Environmental News for This Week

During this week, the EPA and the U.S. Army Corps of Engineers proposed a sweeping revision to the definition of “Waters of the United States” (WOTUS), substantially narrowing federal jurisdiction under the Clean Water Act (CWA). Under the proposed rule, only relatively permanent, continuously flowing surface waters — plus wetlands with a direct continuous surface connection — would retain federal protection; ephemeral streams, many wetlands, ditches, and groundwater would be excluded.

Simultaneously, the EPA issued a final action extending compliance deadlines for certain oil and gas emissions-control requirements under the 2024 New Source Performance Standards (NSPS) and related methane-emissions regulations. The extension delays various monitoring, control, and reporting obligations for new and modified sources.

Legal & Regulatory Implications:

• Entities operating near or modifying waterways — including renewable energy, land development, or hazardous materials clients — must reassess permitting exposure, wetlands-mitigation obligations, and liability under state laws, as federal oversight retreats.

• For companies in oil and gas, and environmental professionals advising them, the compliance delay may provide short-term regulatory relief, but also heightens risk of future enforcement uncertainty — especially if regulators or states later tighten rules.

The combined effect of these developments signals a pivot in federal environmental oversight toward narrower protections, increased reliance on state regulation, and delayed enforcement burden for certain industries.

Workplace Safety News This Week

This week — the week of December 1, 2025 — the most significant workplace-safety issue in the United States remains the persistent failure to implement adequate fall protection. The Occupational Safety and Health Administration (OSHA) released its preliminary 2025 data showing that violations of its “Fall Protection – General Requirements” standard (29 CFR 1926.501) again top the list nationwide, with 5,914 citations — marking the 15th straight year this hazard leads.

The prevalence of fall-related citations — and the additional top-10 entries for fall-protection training, ladders, scaffolding, and other elevation-related hazards — underscores a systemic failure: too many employers continue to expose workers to preventable fall risks, across construction, maintenance, warehousing, and other sectors.

From a legal and compliance perspective, this persistent non-compliance exposes employers to significant risk: regulatory penalties, potential civil liability for injuries or fatalities, increased insurance costs, and reputational harm. Moreover, recurring violations suggest a lack of effective safety culture, training, and hazard remediation — conditions that could support claims of gross negligence if an incident occurs.

In short: despite decades of regulation and repeated enforcement efforts, fall hazards — especially failures to provide guardrails, harnesses, nets, or safe scaffolding/ladder use — remain the single largest workplace safety crisis in the U.S. this week.

Global DG Transport Regulatory Update

IHMM Global DG Transport Compliance Matrix (2025–2026)

IHMM Certificant Compliance Checklist

§1. United States — PHMSA / International Alignment & Enforcement Watch

• While there have been no newly published final regulations this week amending 49 C.F.R. Parts 171-180, industry stakeholders should take note of continuing international momentum: the global DG transport regime remains dynamic, especially in modal-intersections such as air and sea, which ultimately affect U.S. exports and imports.

• For air freight, the IATA 2025 Dangerous Goods Regulations (DGR), adopted globally earlier this year, remain operative and represent current best-practice standards for shippers using U.S. gateways.

• U.S.-based exporters and freight forwarders should ensure that U.S. Haz-Mat documentation, packaging and shipping practices—particularly for lithium or sodium-ion batteries and battery-powered equipment—are consistent with IATA DGR (air), IMDG Code (sea), and the UN Model Regulations foundations that underlie ADR, even if the HMR does not explicitly mirror all of those provisions.

Legal import: Although no new HMR rule is active, failure to voluntarily align with global standards may expose U.S. exporters to increased risk of rejection, liability, or loss of insurance coverage when consignments transit non-U.S. jurisdictions under ADR/UN-based frameworks.

§2. Europe — ADR 2025 in Force; 2027 Cycle Looms

• The 2025 edition of ADR, as consolidated in ADR 2025 (ECE/TRANS/352), remains the controlling technical instrument for road-based DG transport in ADR Contracting Parties. Its amendments (including new UN entries, packaging, waste/asbestos provisions, battery/vehicle-battery rules) are now fully operative.

• According to recent commentary from the International Road Transport Union (IRU), the next ADR revision cycle (targeting 2027) is already on the horizon. Discussion topics will include carriage by battery-electric vehicles, reverse-logistics (repacked or returned DG), and treatment of undeclared DG in supply-chains.

• For EU-based operations, this period marks a transition from “adoption phase” to full compliance and enforcement phase. Operators and compliance managers should audit vehicle approvals, driver training records, DG documentation, packaging, and labels to ensure conformity.

Legal import: As of December 1, ADR 2025 is the operative standard. Parties should treat unamended or outdated documentation, vehicle configurations, or packaging as non-compliant risk. Further, the 2027 revision cycle is effectively “live,” so contractual terms and internal SOPs should include revision-control language to anticipate future amendments.

§3. Asia & Global Modal Overlap — UN / IATA / IMDG as De Facto Benchmark

• No major new ADR-type road-transport law emerged this week in Asia. However, given the transmodal nature of modern supply chains, the applicability of the UN Model Regulations (via air or sea), and 2025 IATA updates, remains critical.

• Stakeholders shipping lithium / sodium-ion batteries, battery-powered vehicles, or sensitive DG cargo should apply the current IATA DGR and IMDG Code protocols; these draw on the same UN Model Regulations that underlie ADR, ensuring global uniformity.

• For Asian carriers or shippers operating road legs under local law, it is prudent to align internal procedures with the “global standard” (UN/ADR) even before domestic adoption. This serves both risk mitigation and future-proofing.

Legal import: For DG consignments crossing multiple borders and transport modes, compliance can no longer be judged by domestic law alone: global UN-based standards (IATA, IMDG, ADR when applicable) now set de facto expectations. Legal counsel should treat these as default standard-of-care benchmarks when drafting contracts and indemnities.

§4. Africa — Status Quo, but Global Trends Filter In

• No new pan-African ADR or UN-derived DG regulation was publicly promulgated this week. Many African states continue to rely on a patchwork of national hazardous-substances and transport laws.

• Nonetheless, African exporters/importers linked to global supply chains should monitor upcoming ADR 2027 deliberations, as well as IATA/IMDG developments, because these affect cross-border road, sea, and air carriage—sectors increasing in importance across Africa.

Legal import: Absence of new law does not equal absence of risk. Parties operating in or through Africa should embed global DG standards (UN-based classification/packaging/labeling/documentation) in contracts and SOPs to ensure international acceptability, especially for export consignments.

§5. Central & South America — MERCOSUR and Regional DG Regime Snapshot

• The regional framework MERCOSUR Agreement on the Land Transport of Dangerous Goods remains the primary DG instrument for over-the-road transport among many South American states. MERCOSUR’s DG agreement is structurally analogous to ADR: it uses the same UN hazard classes, UN numbering, packaging, marking and documentation conventions. UNECE’s regional-analysis documentation lists MERCOSUR as the applicable DG regime for intra-block transport.

• As of 2025, ADR 2025 and the updated UN Model Regulations are the global reference points. Although MERCOSUR does not automatically adopt all ADR amendments contemporaneously, its reliance on UN-based classification and its general structural alignment mean many ADR-class consignments remain technically compatible under MERCOSUR-based regulation.

• For shipments between South American states—or international shipments transiting MERCOSUR territory—shippers, forwarders, and legal counsel should carefully verify that packaging, documentation, and labeling align with both UN model requirements and any MERCOSUR-region national implementations (since local transposition can vary).

Legal import: For carriers or consignors operating or contracting across South America and outside Europe, ADR should be regarded as a technical benchmark rather than a binding obligation. Contracts should reference compliance with the current UN Model Regulations (by revision number) and mandate that all transport documentation and packaging meet those standards, to maximize international acceptance and minimize liability risk.

§6. Overarching Observations

1. Global standard of care evolving — not just national law. As of December 1, 2025, the DG transport regime globally is increasingly unified around the 2025 IATA/UN/ADR standards — especially for new technology goods (e.g., sodium-ion batteries, battery-powered vehicles) and waste/asbestos carriage. Entities must evaluate compliance not only against domestic law but against global norms.

2. Contract drafting must reflect dynamic revision cycles. With ADR in force (2025 version) and 2027 amendment cycle already underway, supply-chain contracts should tie DG compliance to document edition (by UN revision number or ADR volume) and include audit & change-control clauses.

3. Insurance exposure, liability and enforceability depend on global/regional-level compliance. For multi-modal or multi-jurisdiction consignments (e.g., a U.S.-origin lithium battery shipment to Europe via sea + road), compliance with the UN/IATA/IMDG/ADR stack is critical. Lack of alignment can jeopardize insurer coverage or result in enforcement sanctions.

4. Training, documentation and packaging are now the compliance battleground. In 2025-2026, regulators and carriers alike are focusing on whether packaging conforms to updated UN codes, vehicles meet ADR/UN design standards, and documentation (DG declarations, special provisions, UN numbers, emergency info) is complete and current.

Anonymous Reporting Systems

In this excerpt from our podcast series, Understanding Firearm-Related Injury and School Violence, Dr. Libby Messman explains key policies and research findings in violence prevention:

We need to understand what aspects of anonymous reporting systems are effective and what schools need in order to support students’ and teachers’ usage of these systems. Learn more here.

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School Safety Communications Planning Guide

As a school safety leader, you may be faced with widespread misinformation and polarized public opinions. These often leave your local school boards, administrators, teachers, and parents with mixed messages that make it difficult to discern the truth. According to a 2018 MIT Sloan study, false information is 70% more likely to be retweeted than the truth, causing it to reach more people faster than the truth.

You can help prevent incorrect information sharing and create a positive school climate by initiating preemptive conversations about misinformation and disinformation. Students and families are vulnerable to these types of incorrect information, so it is important to discuss these issues in your school and the community.

One way to be prepared to respond appropriately to incorrect information is to create a crisis response communications plan. You can use preplanned and scripted messages to prevent or stop the spread of inaccuracies on social media platforms.  Learn More

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External Opportunities

12/17 – Preventing Mass Attacks in Our Communities
Hosted by the U.S. Secret Service

1/21/26 – Enhancing School Safety Using Behavioral Threat Assessment
Hosted by the U.S. Secret Service

2/18/26 – Preventing Mass Attacks in Our Communities
Hosted by the U.S. Secret Service

3/18/26 – Enhancing School Safety Using Behavioral Threat Assessment
Hosted by the U.S. Secret Service

4/15/26 – Preventing Mass Attacks in Our Communities
Hosted by the U.S. Secret Service

5/20/26 – Enhancing School Safety Using Behavioral Threat Assessment
Hosted by the U.S. Secret Service

Recent News from the European Chemicals Agency

• REACH-IT ready to receive reports on microplastics emissions 

• Current activities on restrictions: aromatic brominated and organophosphorus flame retardants 

• Testing proposals 

• Consultations on candidates for substitution and derogations to exclusion criteria 

• Highlights of the November Forum meeting 

• General Court partly annuls Board of Appeal decision on compliance check 

• REACH Committee meeting in December – draft agenda available 

• Biocides decisions