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 Government Relations Actions in 2025

Coalitions

IHMM participated in the following coalitions during 2025.

• American Society of Association Executives [ASAE] Advocacy Council
• Community Impact Coalition in Washington
• The Workplace EHS Coalition (formerly known as the Intersociety Forum) 
• Professional Certification Coalition
• Tomorrow’s Workforce Coalition

Coalition Letters to Congress and the President

1. IHMM, Workplace EHS Coalition, Write to Congressional appropriators concerning OSHA/NIOSH funding
2. IHMM, Workplace EHS Coalition Write to Congressional appropriators and the President on the critical importance of prioritizing worker safety in the federal budget
3. IHMM, ISF Letter to Congress on the Government Shutdown
4. IHMM, ISF Advocacy for U.S. Chemical Board Funding
5. IHMM NSC Coalition Letter to Congressional Appropriators
6. 460 Friends of NIOSH Coalition Letter Here
7. Read the final SWANA End of Life Op-Ed here
8. OSHA 25-Member Coalition Letter Here
9. Here is the Intersociety Forum “Driving Business Growth and Profitability Through Modern Occupational Environmental, Health and Safety Practices” document [Sept 2025].

Comments Filed in Federal Regulatory Actions

1. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Revision to Regulation – IHMM Comments Filed December 8, 2025
2. National Emission Standards for Hazardous Air Pollutants From Hazardous Waste Combustors: Residual Risk and Technology Review; Withdrawal of Proposed Revisions to Standards for Periods of Malfunction – Due 12/26
3. EPA – National Emission Standards for Hazardous Air Pollutants – IHMM Comments Filed November 16, 2025
4. OSHA – Construction Illumination – IHMM Comments Here Filed October 26, 2025
5. OSHA – Amending the Medical Evaluation Requirements in the Respiratory Protection Standard for Certain Types of Respirators – IHMM Comments Here Filed October 14, 2025
6. OSHA – Interpretation of the General Duty Clause: Limitation for Inherently Risky Professional Activities  – IHMM Comments Here Filed October 14, 2025
7. DOT – Hazardous Materials: Remove Redundant List of U.S. EPA CERCLA Hazardous Substances – IHMM Comments Filed August 28, 2025
8. DOT – National Freight Strategic Plan 2025 Update: Request for Information – IHMM Comments Filed August 14, 2025
9. PHMSA –  PHMSA’s ANPRM: Mandatory Regulatory Reviews – IHMM Comments Here Submitted August 1, 2025
10. US DOT Regulatory Information Request –IHMM Comments Here Filed May 5, 2025
11. OSHA Proposed Heat Rule – IHMM Comments Here Filed January 13, 2025

Tomorrow’s Workforce Coalition Legislation Signed Into Law

After modifications in the Senate to win over Sen. Murkowski (R-AK) and the removal of a few provisions deemed invalid by the Parliamentarian, the Senate passed their version of H.R. 1: To provide for reconciliation pursuant to title II of H. Con. Res. 14 on Tuesday, July 1, 2025. The House then passed the Senate-amended version of HR 1 on Thursday, July 3, 2025.

The President signed that legislation into law on Friday, July 4, 2025.

What Is a “529” Plan and How Does It Work?

On July 4, 2025, President Trump signed into law legislation created by the Tomorrow’s Workforce Coalition, of which IHMM is a part, that expands the permissible uses of an IRS 529 plan to include certain expenses relating to acquiring and maintaining a professional certification.

An IRS 529 plan is a tax-advantaged savings vehicle designed to encourage saving for future education costs. Named after Section 529 of the Internal Revenue Code, these plans are administered by states or educational institutions and offer tax benefits to the contributor and beneficiary when used for qualified education expenses.

Learn more here

PHMSA – ANPRM HM-266 – Highly Automated Transport Systems – CHMMs and CDGPs

Environmental News for This Week

During the week of December 15, 2025, several notable federal environmental developments emerged with regulatory, intergovernmental, and enforcement implications.

First, the United States and Mexico executed a bilateral agreement to address the longstanding Tijuana River sewage crisis, committing to coordinated infrastructure investment, enhanced monitoring, and long-term planning to reduce cross-border pollution in the Pacific near San Diego. This agreement, facilitated by the U.S. Environmental Protection Agency, reflects expanded cooperative enforcement and may impact future civil or administrative liability for transboundary contamination.

Second, the EPA approved Tennessee’s Regional Haze Plan under the Clean Air Act, recognizing that the state’s strategy meets statutory visibility improvement requirements for national parks and wilderness areas. The approval represents contemporaneous federal-state coordination and provides clarity on compliance for regulated sources of sulfur dioxide and nitrogen oxides in the region. Environmental Protection Agency

On the rulemaking front, the EPA continues delaying proposed perchlorate limits in drinking water, shifting publication to early 2026 due to administrative impacts from the federal funding lapse. This postponement extends regulatory uncertainty for public water systems and industrial stakeholders subject to potential future standards under the Safe Drinking Water Act. Circle of Blue

Collectively, these actions underscore the evolving compliance landscape — marked by international agreements, cooperative state implementation of clean-air law, and deferred federal rulemaking — with meaningful enforcement and planning implications for regulated entities.

Workplace Safety News This Week

This week (week of December 15, 2025), the most significant U.S. workplace-safety issue centers on OSHA’s intensified enforcement actions, underscoring regulatory accountability and legal risk for employers. Federal OSHA has cited a Connecticut earthwork contractor for repeated excavation and safety violations, proposing more than $1.2 million in penalties after a follow-up inspection found persistent hazards despite prior warnings — signaling OSHA’s willingness to escalate fines for recalcitrant violators. https://www.wfsb.com

In parallel, OSHA has issued seven letters of interpretation clarifying how key safety and health requirements apply in specific workplace contexts. These guidance letters are intended to promote consistent enforcement and reduce regulatory ambiguity for employers — particularly in areas such as confined-space hazards and recordkeeping obligations. Healthesystems

Taken together, these developments highlight two intertwined themes: (1) robust enforcement against employers with recurring safety failures, and (2) proactive compliance assistance through clarified regulatory interpretation. For legal counsel and safety managers, the Connecticut citation serves as a warning that inadequate hazard remediation can lead to substantial civil penalties, while the interpretation letters present an opportunity to align internal policies with OSHA’s current enforcement lens.

Key takeaway: OSHA is actively enforcing existing standards and refining interpretive guidance to enhance clarity, consistency, and employer compliance across industries.

Global DG Transport Regulatory Update

IHMM Global DG Transport Compliance Matrix (2025–2026)

IHMM Certificant Compliance Checklist

Week of December 15, 2025

I. Executive Summary

The week of December 15, 2025, marks the close of an active year in global dangerous-goods regulation. Rather than introducing sweeping new treaty amendments, regulators across jurisdictions focused on consolidation, enforcement posture, and positioning for the next UN/UNECE amendment cycle.

With ADR 2025 fully operative, IMDG Code Amendment 42-24 nearing mandatory status, and the UN Model Regulations revision cycle advancing, the regulatory emphasis this week is on compliance maturity, particularly for battery technologies, waste transport, and undeclared dangerous goods.

II. United States — Enforcement Maturity and International Alignment

A. PHMSA Enforcement Focus Continues

During the week of December 15, PHMSA continued implementing its data-driven hazardous materials inspection and enforcement framework, now moving from rollout to steady-state operations. While no new amendments to 49 C.F.R. Parts 171–180 were published this week, the agency’s activities reflect sustained emphasis on:

• Lithium-ion and sodium-ion batteries, including battery-powered equipment and vehicles;

• Cylinder and pressure-receptacle manufacturing and requalification;

• Undeclared or misdeclared hazardous materials, especially in parcel and e-commerce channels; and

• Repeat violators, identified through historical enforcement data.

Legal Significance

From a legal standpoint, PHMSA’s actions reinforce a central principle: enforcement policy shapes regulatory reality. Although the Hazardous Materials Regulations have not been textually amended, the enforcement environment now demands documentation, packaging, and training practices that align closely with UN Model Regulations and ADR-derived international standards, particularly for exporters whose shipments enter ADR jurisdictions.

III. Europe — ADR 2025 Normalization and Forward Planning

A. ADR 2025 Embedded in Practice

By mid-December, ADR 2025 is no longer transitional but fully normalized across Contracting Parties. During the week of December 15, European authorities continued issuing operational guidance and inspection reminders addressing:

• Correct application of new battery-related UN entries, including sodium-ion batteries;

• Revised provisions governing waste and asbestos transport;

• Documentation and equipment requirements for vehicles using alternative propulsion technologies; and

• Driver training and certification continuity under ADR Chapter 8.2.

These communications, while interpretive rather than legislative, have immediate compliance consequences.

B. ADR 2027 Work Programme Advances Informally

At the same time, the ADR 2027 amendment cycle is gaining momentum. Delegations and industry stakeholders are actively developing proposals concerning:

• DG carriage by battery-electric and hybrid heavy vehicles;

• Harmonisation of reverse-logistics and returned-goods flows;

• Potential refinement of limited quantity (LQ) thresholds and exemptions; and

• Enhanced treatment of undeclared DG in parcel and e-commerce distribution networks.

Legal Significance

For European operators and international shippers, the message is twofold: ADR 2025 compliance is now expected without qualification, and future contracts and compliance systems must be flexible enough to accommodate further tightening in ADR 2027, particularly in battery-related and consumer-distribution contexts.

IV. Asia — Regulatory Quiet, Operational Expectations Rising

A. Limited Formal Rulemaking This Week

No major new national DG transport statutes or regulations were promulgated in key Asian jurisdictions during the week of December 15.

B. International Standards Drive Practice

Despite the absence of domestic rulemaking, Asian shippers and carriers are experiencing heightened compliance expectations driven by:

• Continued work under the UN Sub-Committee of Experts on the Transport of Dangerous Goods, shaping future UN Model Regulations;

• Carrier and port enforcement of IMDG Code Amendment 42-24 practices ahead of its mandatory date; and

• Uniform application of ICAO Technical Instructions / IATA DGR 2025–2026 for air transport.

Legal Significance

In Asia, carrier acceptance and international norms are increasingly determinative of compliance outcomes. From a legal-risk perspective, UN- and ADR-aligned documentation and packaging now function as the baseline standard of care, even where domestic law has not yet been formally updated.

V. Africa — Gradual Convergence Through Enforcement and Trade Practice

A. No New DG Legislation Reported

No African jurisdiction enacted a significant DG-specific statute or regulation during the week of December 15.

B. Practice-Driven Alignment with UN/ADR Norms

Nevertheless, African ports, customs authorities, and transport operators continue to tighten controls through:

• DG documentation requirements reflecting UN classification and numbering;

• Maritime acceptance criteria aligned with IMDG 42-24; and

• Increased scrutiny of battery and hazardous-waste consignments.

Legal Significance

For multinational operators, Africa illustrates a broader trend: practical enforcement and trade requirements are converging on UN/ADR standards, even where legislative updates lag. Compliance failures may therefore result in operational disruptions rather than formal citations.

VI. Central & South America — MERCOSUR Stability, National Enforcement Acceleration

A. MERCOSUR DG Framework Remains Unchanged

At the regional level, no new MERCOSUR decisions on DG transport were adopted this week. The governing instrument remains the MERCOSUR Agreement on the Land Transport of Dangerous Goods, as modernized by CMC Decision 15/2019, which is explicitly tied to the UN Model Regulations.

B. National Authorities Increase Oversight

More consequential are national-level enforcement and interpretive developments observed this week:

• Argentina: Transport authorities continue heightened inspections of battery-powered equipment and vehicles under the UN-aligned Resolution 64/2022 framework.

• Brazil: ANTT offices are refining internal guidance on classification and documentation for sodium-ion batteries under ANTT Resolution 5.998/2022.

• Colombia: The DG transport registry that became effective in late November is now being actively enforced, imposing concrete reporting and traceability obligations.

Legal Significance

While MERCOSUR provides a harmonized technical baseline, compliance risk is increasingly national and enforcement-driven. Shippers must verify alignment not only with the regional agreement but also with each country’s implementing measures and inspection practices.

VII. Overall Legal Assessment

For the week of December 15, 2025, global DG regulation is characterized by:

1. Sustained enforcement pressure without new statutory text (United States, South America);

2. Full operational consolidation of ADR 2025 (Europe);

3. Ongoing international norm-setting under UNECE and the UN; and

4. Rising operational compliance expectations driven by carriers and ports (Asia and Africa).

Across all regions, battery technologies, hazardous waste, and undeclared dangerous goods remain the principal regulatory stress points.

VIII. Conclusion

The close of 2025 underscores a central reality of dangerous-goods law: regulatory risk increasingly arises from enforcement, interpretation, and international harmonization rather than headline legislation alone.

For IHMM certificants and DG professionals, prudent compliance now requires treating ADR 2025, the UN Model Regulations, IMDG Code Amendment 42-24, and ICAO 2025–2026 as the operative global standard of care—regardless of jurisdiction. Organizations should review documentation, training programs, packaging approvals, and contractual language accordingly as they prepare for 2026 and the next amendment cycle.

Cultivating a Supportive School Climate

School climate refers to the overall atmosphere of school life, which significantly affects the experiences of everyone in the school community. A positive and supportive school climate plays a crucial role in promoting healthy youth development and is also a strong predictor of school safety. Learn more here.

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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

• Enforcement Forum finds non-compliance in imported substances, mixtures and products
• Enforcement Forum’s 2025 open session presentations published
• Member States plan to evaluate 27 substances in 2026-2028
• Non-Cr(VI) applications for authorisation prioritised ahead of REACH restriction
• Consultation on a candidate for substitution
• Deadline extended: Call for evidence for substances in batteries and waste batteries
• ECHA Industry Portal is live
• Reminder: Maintenance break on 12-15 December 2025
• Court dismisses action against European Commission regarding biocidal active substance approval
• Updates to EUCLEF
• Nanopinion: Atomically-thin optical cavities merging quantum materials and nanophotonics