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

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Inside IHMM

Q&A with IHMM Certificant Insider

Patrick A. Ryan, CHMM, CIH, CSP
Hazardous Materials Manager
Montana State University

What or who motivated you to earn an IHMM credential?

I have always seen the extreme value of credentials. From my time preparing for my Hazmat career as a university student in the 1990s to the present, I have always looked to the CHMM as the necessary credential to be taken seriously as a Hazmat professional in the widest range of professional domains. Many of my top mentors were certified and encouraged me to pursue certification. The CHMM has always been the top credential in the hazardous materials and hazardous waste management worlds.

Are there any opportunities you’re looking forward to as a result of earning an IHMM credential?

Being a CHMM has opened an array of opportunities in my career, especially in recent years, and in combination with other prestigious credentials. For example, I would probably not be on the CHMM Examination Committee if I were not a CHMM. Being certified gives you a seat at the table you might otherwise not have and adds a lot of credibility. Presenting at the national level and being a Hazmat educational consultant who trains professional first responders absolutely necessitates being certified.

What would you say to someone who is considering earning an IHMM credential?

Certification matters, especially in today’s crowded job market. Certification shows you have both a commitment to learning and to the pursuit of excellence. I learned early in my career that in many circles, you will not be taken seriously unless you are certified. To have maximum impact, I became certified. Maintaining my certification is both a continuation of my learning journey and represents my commitment to sustained excellence as a hazardous materials professional. Certification will always set you apart from the crowd.

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 Files Comments in EPA PFAS Rulemaking

IHMM Comments

Federal Register

Risk Matrix for CHMM/CMHP and the Proposed Rule

PFAS Guidance Concerning 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 Issues Briefing Paper for IHMM Certificants – EPA Retirement of Management Method Code H141 and Introduction of New “S” Codes for Hazardous Waste Reporting

Executive Summary

The U.S. Environmental Protection Agency (EPA) has announced a major revision to hazardous-waste reporting under the Resource Conservation and Recovery Act (RCRA). Effective January 1, 2027, EPA will retire Management Method Code H141, historically used for “Storage and Transfer,” and replace it with a suite of new “S-series” codes intended to provide more precise reporting of waste handling activities before final management.

The new S-codes are already active in EPA’s RCRAInfo platform, meaning facilities may begin using them immediately and are strongly encouraged to begin transitioning well before the 2027 deadline.

For IHMM certificants—many of whom routinely interact with RCRA reporting systems, hazardous-waste vendors, program audits, and facility-level compliance operations—this change is material. Facilities will need to update internal procedures, software interfaces, manifests, and personnel training.

Read more here

Environmental News for This Week

During the week of December 8, 2025, two developments significantly reshape environmental compliance and regulatory risk in the United States:

1. EPA Proposes Changes in PFAS Reporting. As indicated in the article above, 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.
2. EPA Revises Risk Assessment of Formaldehyde – Loosening Health Standards The EPA announced that it will substantially increase the “safe” exposure threshold for Formaldehyde, effectively doubling the amount considered non-hazardous — a shift long sought by industry interests. This change likely reduces liability for manufacturers and users, but simultaneously exposes downstream permit holders, employers, and consultants to heightened reputational risk, potential litigation, and stakeholder scrutiny under consumer-protection and toxic-substance laws.
3. EPA’s Proposed Rollback of Clean Water Act (“WOTUS”) Protections Shows Forward Momentum. The ongoing effort to narrow the definition of Clean Water Act (CWA) jurisdiction continues to draw public and legal attention. Under the rule, many seasonal streams, ephemeral flows, and isolated wetlands risk losing federal protection — a move that threatens to shift compliance burdens to state and local entities and expose developers, landowners, and environmental consultants to complex, fragmented liability.

Legal & Regulatory Implications:

• Entities using or emitting regulated chemicals (e.g., formaldehyde) should reassess disclosure, compliance, worker safety, and client-service obligations immediately.

• Those engaged in land development, remediation, wetlands mitigation, or aquatic-related licensing must brace for shifting jurisdictional boundaries, increased legal uncertainty, and the need to navigate a mosaic of state-level protections when federal oversight recedes.

Workplace Safety News This Week

This week (week of December 8, 2025), the principal workplace-safety issue in the United States centers on renewed regulatory and legal pressure on the Occupational Safety and Health Administration (OSHA), as two major industry groups filed suit challenging OSHA’s authority to promulgate workplace-safety regulations.

Legal Context & Risk

• In the case filed by the Texas International Produce Association and the Texas Vegetable Association, plaintiffs contest that Congress unconstitutionally delegated broad rule-making power to OSHA by authorizing it to impose “reasonably necessary and appropriate” standards without more specific statutory constraints.

• If a court (presided over by Judge Matthew Kacsmaryk) accepts that argument, it could significantly curtail OSHA’s ability to issue and enforce safety standards — potentially undermining decades of workplace protections.

Implications for Employers and Workers

• Regulatory uncertainty could stall adoption of future standards, reduce compliance oversight, and potentially erode established protections — especially in high-risk industries.

• Employers might face short-term relief from new obligations, but longer-term liability risks could increase where safety measures remain outdated or inadequate.

• Workers may face heightened danger if critical regulatory safeguards become legally vulnerable or enforcement slows.

In sum: the most consequential workplace-safety development this week is not a specific accident or hazard — but a legal challenge to the bedrock authority of OSHA itself. The outcome could reshape the regulatory landscape and influence how workplace safety is governed nationwide.

Global DG Transport Regulatory Update

IHMM Global DG Transport Compliance Matrix (2025–2026)

IHMM Certificant Compliance Checklist

Week of December 8, 2025

I. United States — PHMSA Enforcement Priorities Continue to Reshape DG Compliance

Although PHMSA has not issued a new NPRM or final rule this week, U.S. DG regulation is still materially changing due to enforcement policy, not text.

A. Data-Driven Enforcement Framework Enters Operational Phase

PHMSA’s new enforcement-prioritization memorandum, released in late November, is now being applied across regional offices. This week marks:

• The first coordinated inspections explicitly targeting lithium and sodium-ion battery shippers,

• Heightened oversight of cylinder manufacturers and requalifiers,

• Targeted audits of undeclared hazmat shippers operating in e-commerce channels, and

• Increased monitoring of entities with repeat hazmat violations.

B. Legal Significance

• Although 49 CFR Parts 171–180 have not changed, the probability of inspection and civil penalties has increased dramatically for these categories.

• U.S. exporters sending DG to ADR-jurisdictions must now demonstrate not just regulatory compliance but documentation controls consistent with ADR / UN expectations, especially for battery or waste shipments.

Counsel’s note: Enforcement developments create de facto regulatory change. Regulated entities should treat PHMSA enforcement priorities as functional amendments to the Hazardous Materials Regulations (HMR).

II. Europe — ADR 2025 Consolidation; WP.15 and RID/ADN Alignment Work Intensifies

This week is a “quiet but consequential” period in the European DG regime.

A. ADR 2025 Fully Operational, Supplemented by National Clarifications

Across ADR Contracting Parties, regulators have begun publishing guidance circulars and ministerial notices clarifying:

• The documentation requirements for the new battery-related UN entries,

• Waste-transport obligations under revised ADR 2.1.3,

• Vehicle/equipment requirements under ADR Part 9 as applied to mixed-propulsion vehicles, and

• Transitional allowances for existing packaging and tank approvals.

While not amendments, these national publications materially affect compliance.

B. ADR 2027 Work Programme Formally Underway

Following WP.15’s autumn session, several delegations have now circulated non-papers and working drafts on:

• DG carriage in battery-electric heavy trucks,

• Harmonisation of reverse-logistics waste flows across the EU,

• A possible restructuring of ADR’s limited quantity (LQ) provisions, and

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

Legal Significance

Even without formal treaty amendments this week, ADR remains in an active development cycle. Operators should assume that the 2027 edition will include new and more detailed rules for:

• Battery-powered vehicles and traction batteries,

• Waste/asbestos transport, and

• Emerging battery chemistries (including sodium-ion).

III. Asia — Quiet Rulemaking Week, but Global Standards Are Shifting the Compliance Baseline

A. No New National DG Regulations Announced This Week

China, India, Japan, and ASEAN states did not publish new DG transport decrees during the week of December 8.

B. However: UN Model Regulations Revision Work Is Ongoing

With the UN Sub-Committee of Experts meeting continuing into December, Asian regulators and industry associations are preparing to harmonize 2026–2027 national regulations with:

• Updated battery entries,

• Hazardous waste carriage standards, and

• Revised test criteria for certain Class 4 and Class 9 commodities.

C. Legal Significance

Even when domestic statutes are unchanged, the standard of care for Asian shippers is rising because:

• International carriers servicing Asia increasingly require ADR / UN Model-compliant documentation,

• Port authorities are tightening battery-shipment acceptance criteria, and

• Air carriers continue applying IATA DGR / ICAO TI rules without national exceptions.

IV. Africa — Limited Legislative Activity but Rising Reliance on UN/ADR Standards

A. No Major DG Statutes or Regulations Published This Week

African DG law remains primarily national, and no state published a new DG-specific rule during this week.

B. Increasing Convergence with Global Norms

However, African customs authorities and port operators continue to:

• Require DG declarations consistent with UN numbering and ADR-style classification,

• Implement DG acceptance checks mirroring IMDG 42-24, and

• Review battery-related cargo more strictly.

Legal Significance

For multinational operations, Africa is moving toward implicit adoption of ADR/UN frameworks via port rules, carrier requirements, and customs-clearance processes — even without explicit legislative updates.

V. Central & South America — MERCOSUR Framework Stable; National Implementation Pressures Growing

A. MERCOSUR DG Agreement Continues to Serve as the Regional Backbone

No new MERCOSUR DG decision was published this week. The operative instrument remains:

• The MERCOSUR Agreement on the Land Transport of Dangerous Goods, modernized by CMC Decision 15/2019, which is explicitly tied to specific revisions of the UN Model Regulations.

B. National-Level Developments Are More Significant Than Regional Ones

This week, several national authorities have issued internal or informal communications indicating strengthened oversight:

• Argentina — Transport inspectors increasing scrutiny of battery-powered equipment consignments under the Resolution 64/2022 regime.

• Brazil — ANTT regional offices preparing guidance clarifying how UN 3551/3552 sodium-ion batteries should be classified under ANTT Resolution 5.998/2022.

• Colombia — Industry reminders circulated about the DG Transport Registry entering into force at the end of November; operators now face mandatory reporting obligations for DG movements.

C. Legal Significance

Although no new legislation was issued this week, enforcement tightening is occurring across the region. Shippers must ensure that DG documentation, packaging, and vehicle approvals conform not only to the MERCOSUR agreement but also to each state’s national transposition, which may lag or modify the underlying UN/ADR provisions.

VI. Summary Legal Assessment for the Week of December 8, 2025

The week of December 8 is characterized not by dramatic new regulatory text but by:

1. Escalated enforcement (U.S., South America).

2. Operational consolidation of ADR 2025 (Europe).

3. Global revision work in progress (UN Sub-Committee).

4. International-carrier-driven compliance tightening (Asia, Africa).

Across all regions, battery technologies, hazardous waste, and reverse logistics continue to drive DG regulatory evolution. The absence of published statutory amendments should not obscure the fact that regulators and carriers are raising the operative compliance bar.

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

• Highlights from November BPC meeting 

• New substance evaluation conclusion published 

• Advice on alternative test methods for skin sensitisation 

• New proposals to harmonise classification and labelling 

• New tool to support biocide risk assessment for bees 

• Updated templates for product assessment reports 

• Enforcement Forum's work programme 2026-2027 

• Science seminar: Endocrine disruption activity of selected BPA alternatives 

• Workshop on alternative methods for acute fish toxicity 

• Call for evidence on restriction preparation for aromatic brominated flame retardants 

• Video tutorials help navigate ECHA CHEM 

• Maintenance break on 12-15 December 2025 

• A new study enhances transparency on the safety of nano-enabled textiles 

• Reminder: survey on nanomaterials used as or integrated into flame retardants