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 Files Comments on EPA NPRM 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

The Institute of Hazardous Materials Management [IHMM] filed comments in EPA’s NPRM Docket ID No. EPA–HQ–OAR–2004–0022, Comments on Proposed NESHAP for Hazardous Waste Combustors—Residual Risk and Technology Review; Withdrawal of Proposed Revisions to Standards for Periods of Malfunction (90 Fed. Reg. 50814, Nov. 10, 2025.

Federal Register

IHMM’s Comments are Here

IHMM addressed the statutory and best practices elements of this proposed rule from the perspective of IHMM’s CHMMs and CHMPs, and the comments include a comprehensive compliance-risk matrix of how the proposed rule affects the work of CHMMs and CHMPs.

IHMM also made recommendations to the EPA concerning state-level implementation guidance implementing the proposed revisions to the Hazardous Waste Combustor (HWC) NESHAP resulting from EPA’s Residual Risk and Technology Review (RTR).

As IHMM does with all comments on any agency’s proposed rules, we also highlighted the background and experience of CHMMs and CHMPs by including the credential blueprints of each and outlining the recertification, continuing education, and accreditation standards of IHMM’s credentials. As we want all government agencies to know about our credentials, this background information is an integral part of all of IHMM’s comments in the hazmat, dangerous goods, and safety EHS areas of interest.

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

Since December 23, 2025 to this week, federal environmental regulation continued a pronounced deregulatory trajectory with several high-impact developments bearing legal and compliance risk.

The Environmental Protection Agency’s ongoing proposed redefinition of “Waters of the United States” (WOTUS) remained front and center. Under the proposal, the agency would sharply narrow federal Clean Water Act jurisdiction, potentially excluding the vast majority of wetlands and ephemeral streams from federal protection — leaving approximately 87 % of Wisconsin wetlands and up to 96 % of Ohio wetlands and streams outside federal oversight. This proposal has significant implications for permitting obligations, enforcement exposure, and state-federal jurisdictional interplay.

EPA also advanced modifications to the PFAS reporting rule under TSCA, proposing expanded exemptions — including de minimis concentration and imported articles exclusions — that could reshape manufacturer reporting obligations.

These regulatory actions occur against a backdrop of broader agency direction noted by observers as prioritizing fossil-fuel interests and reduced pollution limits enforcement, further complicating compliance landscapes.

Implications for regulated entities include reassessment of CWA permitting strategies, increased reliance on state regimes, evaluation of PFAS reporting exposures, and heightened litigation risk from environmental and state challengers.

Workplace Safety News This Week

During the final weeks of 2025 and into early 2026, the most consequential U.S. workplace-safety issue has been OSHA’s active regulatory and compliance posture following the federal government shutdown, emphasizing clarifications of enforcement expectations and resumed enforcement operations. OSHA issued seven Letters of Interpretation (LOIs) in late December 2025, which do not create new rules but legally clarify how existing safety and health standards apply in real-world contexts (e.g., confined spaces, recordkeeping, powered industrial trucks, carcinogen controls, hearing conservation, stairway design). These LOIs signal OSHA’s enforcement intent and assist employers in aligning compliance programs with current agency interpretations — a crucial legal reference point in inspection defense and risk mitigation.

Concurrently, OSHA resumed normal enforcement operations post-shutdown and extended contest periods for citations issued during shutdown days, effectively tolling contest deadlines and giving employers additional time to respond, dispute, or seek informal conferences regarding citations.

These agency actions demonstrate OSHA’s dual focus on clarifying compliance expectations and ensuring procedural fairness after a period of enforcement interruption. For legal counsel and safety professionals, the issuance of LOIs and administrative deadline adjustments constitute the most significant workplace-safety developments in this period, shaping enforcement outcomes and compliance strategies nationwide.

Below are the OSHA Letters of Interpretation (LOIs) topics issued in late December 2025 that are most relevant to EHS professionals, CHMMs, CHMPs, CSHMs, CSMPs, and AHMMs—i.e., your industry and credentialing ecosystem—flagged with why they matter legally and operationally.

OSHA Interpretation Topics of Highest Relevance (Dec. 23, 2025–Jan. 4, 2026)

1. Confined Spaces (29 CFR 1910.146)

Why it matters:
OSHA clarified employer responsibilities for hazard evaluation and rescue planning in non-permit and permit-required confined spaces. This directly affects industrial facilities, utilities, labs, and energy operations.
Risk: Misclassification of spaces → serious or willful citations; post-incident liability exposure.

2. Recordkeeping & Injury/Illness Classification (29 CFR Part 1904)

Why it matters:
Clarifications on when injuries must be logged, how to treat restricted duty, and employer responsibility for temporary workers.
Risk: Inaccurate OSHA 300/300A logs → enforcement exposure, credibility issues during inspections, and litigation discovery risk.

3. Powered Industrial Trucks (29 CFR 1910.178)

Why it matters:
OSHA addressed operator training, certification, and workplace-specific hazard assessments.
Risk: Forklift incidents remain a top OSHA fatality driver; training gaps often trigger multi-item citations.

4. Hearing Conservation & Noise Exposure (29 CFR 1910.95)

Why it matters:
Clarification on monitoring requirements and when audiometric testing is mandatory.
Risk: Long-latency occupational illness claims; cumulative compliance failures.

5. Stairways, Walking-Working Surfaces, and Egress (29 CFR 1910 Subpart D)

Why it matters:
OSHA clarified design and maintenance expectations—highly relevant to warehouses, manufacturing, and labs.
Risk: Slip/trip/fall citations; repeat violations increasingly escalated.

6. Carcinogens & Hazard Communication

Why it matters:
Clarifications reinforce employer duty to evaluate exposure, labeling, and training—even when substances are present intermittently.
Risk: Chemical exposure claims; alignment with TSCA, RCRA, and lab safety obligations.

Strategic Takeaway for IHMM-Aligned Professionals

These interpretations collectively signal that Occupational Safety and Health Administration is tightening expectations around documentation, training, and hazard evaluation—without issuing new rules. For credential holders, these LOIs should be treated as de facto enforcement guidance, incorporated into training, audits, exam blueprints, and compliance SOPs.

Global DG Transport Regulatory Update

IHMM Global DG Transport Compliance Matrix (2025–2026)

IHMM Certificant Compliance Checklist

Weeks of December 15, 2025-January 4, 2026

I. Executive Overview

The period between December 15, 2025 and January 4, 2026 marks a regulatory inflection point rather than a rulemaking surge in global dangerous-goods transportation law. With ADR 2025 fully in force, IMDG Code Amendment 42-24 transitioning toward mandatory status, and the UN Model Regulations revision cycle advancing, regulators worldwide have shifted from promulgation to implementation, enforcement prioritization, and preparation for the next amendment cycle.

Across jurisdictions, the dominant themes during this period are:
(1) enforcement maturation, particularly for batteries and undeclared DG;
(2) operational consolidation of 2025-level instruments; and
(3) forward-looking positioning for 2026–2027 amendments under UN and UNECE auspices.

II. United States — Enforcement Policy as the Primary Driver of Change

A. PHMSA Enforcement Posture Solidifies

No new amendments to 49 C.F.R. Parts 171–180 were issued during this period. Nevertheless, U.S. DG regulation evolved materially through enforcement practice rather than statutory text. The Pipeline and Hazardous Materials Safety Administration (PHMSA) continued operationalizing its data-driven inspection and enforcement framework, announced in late November.

During the closing weeks of 2025 and into early January 2026, PHMSA field activity reflected sustained focus on:

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

• Cylinder manufacturing and requalification facilities;

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

• Repeat violators, identified through historical inspection data.

Legal Significance

From a legal perspective, PHMSA’s approach confirms that enforcement policy now functions as a de facto regulatory instrument. Even in the absence of new HMR text, U.S. shippers—especially exporters—are expected to meet UN Model Regulations and ADR-aligned standards for classification, packaging, documentation, and training. Failure to do so increasingly exposes regulated parties to enforcement action and downstream liability.

III. Europe — ADR 2025 Fully Embedded; ADR 2027 in Early Formation

A. ADR 2025 Enforcement and Interpretation

Throughout this period, ADR 2025 (ECE/TRANS/352) was fully operational across Contracting Parties, with national authorities focusing on inspection, clarification, and compliance normalization rather than amendment. Authorities issued guidance and reminders addressing:

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

• Revised provisions for waste and asbestos transport;

• Vehicle and equipment requirements under ADR Part 9, particularly for alternative propulsion systems; and

• Continued validity of ADR driver training certificates under Chapter 8.2.

B. Early Signals for ADR 2027

Simultaneously, work continued quietly on the ADR 2027 amendment cycle. Delegations within the UNECE Working Party on the Transport of Dangerous Goods are developing concepts relating to:

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

• Regulation of reverse-logistics and returned DG flows;

• Refinement of limited quantity (LQ) provisions; and

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

Legal Significance

For European operators and international shippers, this period underscores that ADR compliance is no longer transitional. ADR 2025 represents the settled baseline, while contractual arrangements and compliance systems must remain adaptable to anticipated tightening in ADR 2027, particularly in battery- and e-commerce-driven supply chains.

IV. Asia — Regulatory Quiet, International Standards Ascendant

A. Limited National Rulemaking

Between mid-December and early January, no major national DG transport statutes or regulations were promulgated in key Asian jurisdictions.

B. Carrier and Port-Driven Compliance

Despite limited domestic legislative activity, Asian shippers and carriers experienced rising compliance expectations driven by:

• Ongoing work of the UN Sub-Committee of Experts on the Transport of Dangerous Goods, which is shaping future UN Model Regulations;

• Widespread carrier adoption of IMDG Code Amendment 42-24 practices ahead of its mandatory date; and

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

Legal Significance

In Asia, compliance risk is increasingly determined by international carrier acceptance standards rather than domestic law alone. For legal counsel, UN- and ADR-aligned documentation and packaging now constitute the operative standard of care, even where national legislation has not yet been updated.

V. Africa — Gradual Alignment Through Practice Rather Than Statute

A. Absence of New DG Legislation

No African jurisdiction enacted a major DG-specific statute during this period. National frameworks remain diverse and often embedded within general transport or hazardous-substance laws.

B. Practical Convergence with UN/ADR Norms

Notwithstanding legislative quiet, African ports, customs authorities, and carriers increasingly:

• Require DG documentation consistent with UN classification and numbering;

• Apply maritime acceptance criteria aligned with IMDG 42-24; and

• Subject battery and hazardous-waste consignments to heightened scrutiny.

Legal Significance

For multinational operators, Africa exemplifies a broader trend: practice is converging toward UN/ADR standards ahead of formal legislation. Operational non-compliance may therefore result in shipment refusal or delay even where domestic statutes appear permissive.

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

A. Regional Framework Remains Unchanged

At the regional level, the MERCOSUR Agreement on the Land Transport of Dangerous Goods, as modernized by CMC Decision 15/2019, remained the controlling instrument throughout this period. The agreement continues to be expressly tied to revisions of the UN Model Regulations.

B. National Implementation and Enforcement

More significant were national-level developments:

• Argentina continued intensified inspections of battery-powered equipment and vehicles under its UN-aligned implementation framework;

• Brazil advanced internal guidance clarifying application of UN entries—particularly sodium-ion batteries—under ANTT Resolution 5.998/2022; and

• Colombia moved from transition to active enforcement of its dangerous-goods transport registry, imposing concrete reporting and traceability obligations.

Legal Significance

Although MERCOSUR provides a harmonized technical baseline, compliance risk in South America is increasingly national and enforcement-driven. Shippers must ensure alignment with each country’s implementing measures and inspection practices, not merely the regional agreement.

VII. Overall Assessment

For the period December 15, 2025 through January 4, 2026, global DG transport regulation is characterized by:

1. Enforcement-led change without new statutory text (United States, South America);

2. Full consolidation of ADR 2025 as the European baseline;

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

4. Rising carrier- and port-driven compliance expectations (Asia and Africa).

Across all regions, battery technologies, hazardous waste, and undeclared DG remain the dominant regulatory pressure points.

VIII. Conclusion

The close of 2025 and opening of 2026 confirm 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, the prudent course is to treat ADR 2025, the UN Model Regulations, IMDG Code Amendment 42-24, and ICAO 2025–2026 as the global standard of care, irrespective of jurisdiction. Documentation, packaging approvals, training programs, and contractual controls should be reviewed accordingly as organizations position themselves for the 2026–2027 amendment cycle.

Perspectives On Prevention in Action

Planning Proactively for School Safety

Starting the year with intentional planning helps schools address challenges before they arise. “This time at the beginning of the school year gives us maybe a little bit of an opportunity to think about the year ahead and try to be a little proactive with our planning,” Emily Torres noted. Taking time to review procedures, clarify roles, and strengthen school-community partnerships helps ensure everyone understands their role in maintaining safety. Proactive planning also allows schools to refresh safety conversations with students and staff.

Centering Mental Health and Relationships

School safety extends beyond physical security. Strong relationships and attention to mental health lay a foundation for prevention and recovery. Emily emphasized that “we all have a role to play in school safety, from reminding students about those interactions to making sure that all staff in our school buildings… families and our other adults in the community as well… see this as part of their role.” Implementing trauma-informed practices supports students and staff, creating an environment where concerns are noticed early and addressed effectively.

Engaging Students as Partners

Students play an active role in promoting safety. Co-director Marc Zimmerman remarked, “Building on that, it’s also getting the students involved…they feel ownership, and they help create solutions that actually work.” Whether through peer-led initiatives, safety committees, or informal discussions, elevating student voice strengthens school climate and encourages reporting of concerns.

To watch the entire Spotlight video or explore related resources, click here.

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External Opportunities

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 December RAC and SEAC meetings
• Assessment of regulatory needs reports published
• PFAS draft opinion consultation: guidance for respondents and detailed mapping of uses
• Call for evidence: restriction of PPDs and PDs in rubber tyres
• Screening report published for DOTE and Reaction mass of DOTE and MOTE
• Member State Committee December meeting highlights
• Consultations on harmonised classification and labelling
• New intention and proposals to harmonise classification and labelling
• Consultation on a candidate for substitution and derogation to exclusion criteria
• Fall observed in hazardous chemical trade in 2024
• New web pages on our tasks under the Industrial Emissions Directive
• REACH registration data and C&L Inventory only available in ECHA CHEM
• From science to safety: PBT Expert Group discussed bioaccumulation assessment strategies
• Webinar material and Q&As available
• Call for evidence and public consultation: Evaluation of Biocidal Products Regulation