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

Creating a Collaborative Culture

1,504 different conversations are going on in the IHMM/HMS Collaboration platform this week.

Do you have a problem you need to solve and want the opinions of your colleagues? We created the COLLABORATION platform to enable our certificants to network, learn, and grow from one another.

This is where we collaborate with the best people in their fields, always willing to help one another lessen the stress of our jobs and where we strive as a team to make a difference of which we are proud.

You can collaborate here.

Access to COLLABORATION is through the same username/password you use to access your MYIHMM account. Are you having a problem? Contact Jimmy Nguyen at [email protected]

Washington’s Landscape Changes in January 2025 – Part Two

• Republican Donald J. Trump was elected President on November 5th.
• Republicans in races for the U.S. House have taken the majority with 218 seats with Democrats controlling 212, with 5 seats still to be decided. Speaker Mike Johnson [R-LA 4th CD] will return as Speaker of the House. Republicans will command the Chairs of Committees and set the agenda for the next House of Representatives, beginning January 3, 2024. Democrats elected Hakeem Jeffries [D-NY, 8th CD] as their Minority Leader.
• Republicans in races for the U.S. Senate have won control of the Senate by picking up a net of 4 seats, controlling the Senate with 52 members to the Democrats 47, with the Senate race in Pennsylvania yet to be called. Republicans have elected Senator John Thune [R-SD] as Majority Leader of the Senate to replace Mitch McConnell, with Democrats having elected Senator Chuck Schumer [D-NY] as their Minority Leader.

Major Issues

• Tax Code. Many promises were made concerning the tax code in the election campaigns, with some focus on the 2017 Tax Cuts and Jobs Act and its expiring provisions in 2025. Among the Trump Administration’s priorities are to extend the 2025 expiring provisions, as well as add exemptions from federal income taxes; tip wages, overtime pay, and social security.  Further, Trump floated the idea of replacing the entire revenue stream generated by the tax code with tariffs on imported goods. The U.S. imported $3,8 trillion of goods in 2023, and to replace the tax code revenue with tariffs would require a tariff rate of around 70%. Whether possible, feasible or not, watch for these ideas to be floated in legislation in 2025.
• Budget. The federal budget is approximately $6 trillion. Trump has asked Elon Musk and Vivek Ramaswamy, two campaign supporters, to identify $2 trillion in cuts to the federal budget as the country faces a $35 trillion national debt. 50% of the $6 trillion is Social Security, Medicare, and Medicaid. 20% of the $6 trillion is interest on the national debt. 13.3% of the $6 trillion is national defense. Those three categories comprise 83.3% of the entire federal budget.
• Environmental Protection Agency [EPA]. Trump will nominate former Republican Congressman Lee Zeldin of New York to become his EPA Administrator. Expect Zeldin to pursue rolling back regulations, increasing energy dominance, and giving more incentives for fossil fuel industries. Expect Trump to withdraw from the Paris Climate Accords, and scale back EPA’s efforts in the areas of climate and reducing EPA’s budget.
• Regulatory Reform. Trump supporters Elon Musk and Vivek Ramaswamy are also looking for Executive Branch agencies to eliminate or scale down, reducing the size of the federal workforce. On January 20, 2025, expect incoming White House Chief of Staff Susie Wiles to issue instructions to all federal agencies to freeze all new regulatory proposals until the Trump appointees are in place. Next will come Executive actions repealing executive orders issued by President Biden, followed by legislative proposals to the Republican majorities in Congress to reduce federal agencies and employee counts by legislative action where necessary.

In discussing the tax and budget issues alone in this article, we believe the next 12 months will be unlike any 12-month period in America since the enactment of the 16th amendment to the Constitution in 1913.

IHMM Proposes Changes in Government Recognition of Credentials

1.  IHMM Sent a letter to the U.S. Department of the Interior, National Park Service, concerning the uses of professionally credentialed persons performing work for the Park Service.

2. IHMM Signs Letter Opposing Reductions in OSH Worker’s Pay – The IHMM Government Affairs Committee has agreed to sign a coalition letter opposing reductions in pay for IH and OSH employees. Here is the coalition letter we signed.

• Here is the response we received back from the VA.

3. IHMM submitted comments on OSHA Advisory Committee on Construction Safety and Health (ACCSH): Notice of Meetings concerning OSHA-2024-0002-0007, and highlighted the creation of IHMM’s Certified Pandemic Preparedness Specialist [CPPS] credential.

4. State of Maine Department of Environmental Protection is proposing to update Chapter 851, Standards for Generators of Hazardous Waste. In the current regulation, work is required by a professional engineer. IHMM is proposing to include an environmental professional as defined by 40 CFR §312.10.

All IHMM Government Affairs Projects Are Here

Who Has Been Nominated To Be Secretaries of DOL-DOT-EPA?

Rep. Lori Chavez-DeRemer has been nominated to become the next Labor Secretary. Former Congressman Sean Duffy has been nominated to become the next Transportation Secretary. Former New York congressman Lee Zeldin has been nominated to become the next Administrator of the EPA. Below you will see a short background sketch of each of these key nominees in the Trump Administration that takes office on January 20, 2025.

Beltway Buzz – Ogletree Deakins

The Race to Wrap Up the 118th Congress. The U.S. Congress is back in Washington, D.C., this week after legislators spent last week at home on Thanksgiving break. Legislators are scheduled to remain in town until December 20, 2024, but that date can be moved up or pushed back, depending on how quickly they address their outstanding issues. So what is in store for Congress during this three-week sprint? As the Buzz has mentioned over these recent weeks, funding for the federal government expires in fourteen days (on December 20). There is also the national defense authorization bill, the farm bill, and disaster relief. Finally, of particular significance for the Buzz, the U.S. Senate has made it through another week without acting on the nomination of Lauren McFerran to remain on the National Labor Relations Board (NLRB). However, Senator Charles Schumer (D-NY) has stated publicly that confirming McFerran is one of his “highest priorities.”

DOL Appeals Decision Striking OT Regulations. The U.S. Department of Labor (DOL) has appealed the November 2024 decision of the U.S. District Court for the Eastern District of Texas to strike down the April 2024 overtime rule in its entirety. While nothing is guaranteed, many are expecting the incoming administration to drop the appeal. Keith E. Kopplin, Charles E. McDonald, III, and Zachary V. Zagger have the details.

DOL Proposes Eliminating Subminimum Wage for Individuals With Disabilities. On December 4, 2024, the DOL issued a notice of proposed rulemaking entitled, “Employment of Workers With Disabilities Under Section 14(c) of the Fair Labor Standards Act.” The regulation would eliminate “14(c) certificates” that allow employers to pay subminimum wages to workers with disabilities. When Congress enacted the Fair Labor Standards Act in 1938, this provision was included to ensure that individuals with disabilities could secure employment opportunities. Now, through this proposal, DOL maintains that the certificates are no longer necessary because, “Although it is widely acknowledged that individuals with disabilities continue to face challenges in obtaining equal opportunity and treatment, the extent of legal protections opportunities, resources, training, technological advancements, and supports has dramatically expanded since 1989, when the DOL’s regulation was last substantively updated, to assist individuals with disabilities both in obtaining and maintaining employment at or above the full minimum wage.” Comments are due by January 17, 2025, so the fate of the proposal will ultimately be determined by the incoming administration. Charles E. McDonald, III, and Leah J. Shepherd have the details.

More DOL Regulatory Activity. While the DOL’s Wage and Hour Division appeals its overtime regulations and seeks to eliminate 14(c) certificates, other DOL sub-agencies are pulling back on rulemaking efforts. Here is what is happening:

• Employer “Split Income” Reporting. The DOL’s Office of Labor-Management Standards has officially withdrawn its forecasted “split income” employer reporting regulation. The proposal, which was never made public and appeared on the administration’s regulatory agenda for the first time in July 2024, would have required employers to report their “supervisors’ income on a split basis, that is, the pro rata share of the supervisor’s wages that were spent undertaking the reportable activity.”

• DOL Withdraws Apprenticeship Rule. The DOL’s Employment and Training Administration has officially withdrawn its proposed changes to regulations implementing government-registered apprenticeship programs. The proposal, which was introduced in early 2024, was criticized by many in the business community as being overly burdensome and biased in favor of organized labor.

OSHA Extends Deadline to Submit Comments on Heat Proposal. The Occupational Safety and Health Administration (OSHA) has extended the deadline for stakeholders to submit comments to its proposed standard, “Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings.” The comment docket was scheduled to close on December 30, 2024, but will now close on January 14, 2025. While the brief extension likely has some commenters breathing a sigh of relief, the new deadline will ensure that the docket will close prior to the arrival of the new Trump administration. What the new administration will do with the proposal is unclear at this time, but it assuredly will not be finalized as originally proposed.

Merry Christmas – Federal Shutdown Looms December 20th

Proposed Methods Update Rule 22 Signed by the EPA Administrator

On December 6, 2024, EPA released a proposed rule, titled Clean Water Act Methods Update Rule 22 for the Analysis of Contaminants in Effluent, which would add or revise analytical methods, or test procedures, for measuring pollutants (also called parameters) in wastewater. Specifically, EPA is proposing to add new agency test methods for per- and polyfluoroalkyl substances (PFAS) and polychlorinated biphenyl (PCB) chemicals and add methods previously published by voluntary consensus standard bodies such as ASTM International, or other vendors. When finalized, industries, states, and municipalities would use these methods for reporting under the EPA’s National Pollutant Discharge Elimination System permit program.

EPA’s proposed rule would also withdraw seven PCB mixtures (Aroclor) parameters. In addition, EPA is proposing to simplify the sampling requirements for two volatile organic compounds and make a series of minor corrections to existing tables of approved methods. This proposed rule does not mandate when a pollutant must be monitored nor whether to establish a discharge limit for a parameter. The agency will accept public comments on the proposed rule for 30 days upon its publication in the Federal Register. For more information on this proposed rule, visit the EPA’s Clean Water Act Methods website.

For any questions related to this announcement, please contact [email protected]

Is Water Vapor a Greenhouse Gas?

With much attention given to humans’ climate-warming carbon dioxide (CO2) emissions, you might be surprised to learn that CO2 is not the most prevalent greenhouse gas affecting the Earth’s temperature. Rather, water vapor (H2O) is the most abundant greenhouse gas. Although water vapor is not directly produced by human activity, it significantly contributes significantly to the greenhouse effect. Water’s Role in Supporting Climate Change Water vapor contributes for about half of the greenhouse effect keeping heat from the sun inside our atmosphere. It is arguably the most important greenhouse gas in the climate system due to its relatively high concentrations. For perspective, CO2 makes up about 420 parts per million of our atmosphere—0.04%, whereas water vapor may vary from almost nothing to as much as 3% of a volume of air.

Read more at the ANSI Blog: Is Water Vapor a Greenhouse Gas? https://blog.ansi.org/?p=181067

Read more here

COSTHA, for IHMM and other members, attended the Multi-Association Committee on the Transportation of Dangerous Goods (MACTDG) meeting on November 4, 2024, in preparation for the Transport Canada’s General Policy Advisory Council (GPAC) meetings on November 6, 7 & 20, 2024, which COSTHA also attended.

During the GPAC meeting, Transport Canada (TC) advised that the TDG Directorate was undergoing a reorganization and that resources were sparse. As a result, amendments to the TDG Regulations that stakeholders have been waiting for, such as the Part 12 (Air) & International Harmonization Update (IHU) as well as the Canadian update, are being delayed further. Publication of those 2 amendments in Part II of the Canada Gazette (CG II) is now anticipated for Winter/Spring 2025. Transport Canada also advised that most of the previously proposed changes to Part 2 (Classification) in the IHU will not be part of this amendment (i.e., current Part 2 will remain mostly as is in the TDGR and will not directly reference the UN Model Regulations).

The Canadian Update, originally published in Part I of the Canada Gazette (CG I) in December 2023 is meant to strengthen existing rules, clarify provisions, fix inconsistencies, and introduce new rules in response to concerns raised by stakeholders, inspectors, and local authorities. It includes, but is not limited to, the following:

• Update existing requirements for rail transportation to better align the Canadian buffer car rules with the US;
• Amend the requirements for the transportation of anhydrous ammonia on public roads for agricultural purposes to address ongoing safety concerns; and
• Harmonize the TDGR with the PTNSR, 2015, regarding the transportation of unclassified radioactive waste materials back to the consignors for characterization.

The Part 12 & International Harmonization Update is meant to align the TDGR with the latest editions of the international codes, remove some of the differences between the Canadian and American regulations that create regulatory barriers and impede the seamless transportation of DG across the border. It is also meant to improve clarity of the air transport requirements.

Note that the proposed amendments to Part 6 (Training), which were originally published in Part I of the Canada Gazette in December 2021, will be completely reviewed after comments from stakeholders and a review of the costs associated with its implementation. Transport Canada advised that a “white paper” with is planned to be shared with stakeholders in early 2025. They have also advised that even though safety standard CAN/CGSB-192.3 (Transportation of dangerous goods training, assessment and competency) has been withdrawn, it can still be used as a reference for training purposes.

Management of Hazardous Substances in Port Areas

Containerization, automation, and rising trade volumes are increasing risks in port areas. After some massive incidents, more advice is coming forward.

In June 2023, the OECD organised a seminar series on the Management of Hazardous Substances at Port Areas. The first seminar presented examples from countries on the functioning of their ports with regard to the management of hazardous substances. The second focused on elements of chemical accidents management at port areas. A background report was developed for the seminar series and a survey was conducted amongst delegations, the goal of which was to collect information on what are perceived as the main challenges to managing chemical accidents risks and safety at port areas and possible means for improvement. This document builds on the background report developed for the seminar series supplemented with the conclusions from the seminars as well as the results from the survey.

The report, Management of hazardous substances in port areas, is part of OECD’s series on chemical accidents; it can be downloaded from the OECD website here

Per- and Polyfluoroalkyl Substances (PFAS) News and Information

The attorneys, scientists, regulatory specialists, and business consultants of Bergeson & Campbell, P.C. (B&C^®) and our consulting affiliate The Acta Group (Acta^®) relentlessly participate in and track developments regarding the global regulatory approach to PFAS. We offer this constantly updated library of PFAS resources to help those in the chemical and chemical products industry understand what they need to know and what it means to their business.

EPA and Other Agency PFAS links:

• Recording, transcripts, and slides from EPA webinar “TSCA Section 8(a)(7) Rule: Reporting and Recordkeeping Requirements for PFAS” held January 25, 2024
• EPA PFAS Resource Page
• EPA List of PFAS for TSCA Section 8(a)(7) Rule
• PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024
• EPA PFAS Strategic Roadmap: Research Tools and Resources Webinar Archive
• EPA PFAS Resources, Data and Tools
• EPA PFAS Analytic Tools
• EPA Press Releases Related to PFAS
• European Chemicals Agency (ECHA) PFAS Resource Page
• OECD Portal on Per- and Polyfluoroalkyl Substances (PFAS)
• Minnesota Pollution Control Agency PFAS ban

“Emerging Threats in K-12 Schools.”

Thank you for joining our recent webinar, “Emerging Threats in K-12 Schools.” The conversation was rich with insights on the evolving safety challenges schools face, including the impact of social media, staffing shortages, and the importance of trust and collaboration.

If you missed it—or want to revisit key takeaways—the webinar replay is now available.

Watch the Replay here.

In the webinar, we covered important topics including:

• Key considerations for crowd management
• The role of technology in improving event safety
• How to build a culture of security in school communities

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STOP Grantees – Register Now!

STOP Grantees, join us for the STOP TTA Winter Quarterly Meetings, where we will review key trends from our needs assessment, followed by interactive breakout sessions for collaboration with other grantees. You will also get an exclusive preview of the upcoming Community of Practice platform for continued networking and idea-sharing. Don’t miss this opportunity to share your ideas, exchange knowledge, and contribute to the ongoing conversation about school safety!

• East Region: January 7, 2025 from 1:00 – 2:00 PM ET
• Midwest Region: January 8, 2025 from 12:00 – 1:00 PM ET
• West Region: January 13, 2025 from 3:00 – 4:00 PM ET
• South Region: January 14, 2025 from 12:00 – 1:00 PM ET

Register Now

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School Resource Officer Video Series

School Resource Officers (SROs) play a key role in student safety, serving as advocates, educators, and protectors. This video series provides SROs with practical strategies to connect with students, understand their perspectives, and break down communication barriers to foster a positive presence in schools. Produced in partnership with Katherine Schweit, JD, at Schweit Consulting and Rocket Media Group, the series includes six short videos, each accompanied by an informational poster to reinforce key takeaways. Explore the videos and posters to strengthen your approach to building trust and ensuring a safe, supportive school environment.

Watch Now

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Empowering Education Leaders: A Toolkit for Safe, Ethical, and Equitable AI Integration

The U.S. Department of Education, Office of Educational Technology’s new Empowering Education Leaders Toolkit helps school leaders safely and equitably integrate AI into education. It provides steps for addressing issues like deepfakes, AI-generated school threats, and cyberbullying. The toolkit also offers guidance on protecting student privacy and data, ethical AI use, and presents an overview of federal laws and considerations. These are essential to anchoring and ensuring the use of AI in a safe, secure, and non-discriminatory manner. Explore the toolkit to learn about key considerations for AI in schools.

Learn More Here

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Creating a Culture of Support: Enhancing Staff Resilience in Emergency Situations

Available Now as an On-Demand Webinar

Emergency drills can be stressful for school staff, but integrating mental health support and breaking down safety silos can enhance resilience.

In this on-demand webinar, presenters from the Colorado School of Public Health share strategies for improving emergency drill systems through tailored training, staff feedback, and local resource identification. Participants will learn to customize training for their districts, facilitate effective feedback sessions, and implement changes based on staff input.

Watch Now Here

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OJJDP Launches New Curriculum

The Office of Juvenile Justice and Delinquency Prevention (OJJDP) recently launched the Youth Hate Crimes and Identity-Based Bullying Prevention Curriculum, a key part of its initiative to address hate crimes and bullying. This 10-unit resource helps build protective factors in youth, change harmful behaviors, and educate professionals on using technology to reduce bias. It’s designed for youth-serving organizations, schools, and community groups to raise awareness and prevent identity-based bullying. Explore it today!

Learn More Here

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CISA Launches New Resource

Anonymous threats of violence, especially on social media, are common in K-12 schools. According to the FBI, schools faced over 6,000 such threats in 2022, causing fear, disrupting learning, and straining resources. To address this, CISA has released the Anonymized Threat Response Guidance: A Toolkit for K-12 Schools, which helps schools, law enforcement, and communities respond to and prevent anonymous threats. Explore the toolkit to learn actionable steps for improving school safety. Learn more here.

Controlling Plant and Animal Hazards

Michael Goldman, CIH, CHMM, CSP, CPEA, QEP, didn’t follow the traditional pathway into occupational and environmental health and safety. Now, as a senior safety consultant for Environmental Resources Management and environmental safety and health director with Puldy Resiliency Partners, they still often deal with nontraditional hazards: specifically, dangerous plants and animals.

Goldman grew up in northern Florida, which they described as “a wonderland for anybody who’s interested in insects and reptiles and hazardous plants.” As a child, they collected insects and encountered bark scorpions and luna moths. They graduated from Florida State University with a bachelor’s degree in biology and emphasis on entomology and herpetology and worked briefly at the Smithsonian’s O. Orkin Insect Zoo before moving into industrial hygiene. They’ve remained in the field for the past 35 years.

Read more here.

• Compliance of safety data sheets – still room for improvement
• Lead in PVC restriction kicks in
• Submission of octocrilene restriction proposal postponed
• Testing proposals
• New intention and proposals to harmonise classification and labelling
• Highlights from November BPC meeting
• Member State Committee meets in December
• Tips for preparing simplified SCIP notifications
• Favourable judgments on classification of DTPA and Silanamine
• Judgment Case T-453/22 – General Court dismisses an action against the harmonised classification of DTPA as reproductive toxicant.
• Judgment Case T-449/22 – General Court dismisses an action against the harmonised classification of Silanamine as STOT RE 2 (specific target organ toxicity – repeated exposure).

IHMM-HMS Event Calendar