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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 Outlines Potential Winter Worker Safety Standard (WWSS-2025)

IHMM Stands with the Workplace EHS Coalition to Champion Worker Safety in the FY2026 Federal Budget

Environmental News for This Week

Environmental Protection Agency (EPA) Small-Refinery Waiver Approvals
On November 7, the EPA approved 14 full or partial waivers from the Renewable Fuel Standard’s ethanol-blending obligations and left 15 applications pending.  These decisions may invite legal challenges from biofuel producers or agricultural stakeholders alleging the waivers undermine statutory goals and distort the domestic renewable-fuel market.

Accelerating Climate Science & U.S. Research Capacity Erosion
A new synthesis released concurrently notes that global temperature rise and sea-level increases are proceeding substantially faster than previously projected, and that key scientific tipping points (e.g., coral-reef collapse, Amazon rainforest die-back) may be nearer.  Amid this backdrop, the U.S. is facing reductions in climate-science capacity—raising concerns about the legal defensibility of governmental decision-making, environmental impact assessments, and disclosure obligations.

Conclusion:
From a legal-risk standpoint, these developments highlight heightened exposure in two sectors: renewable-fuel compliance and climate-science sufficiency for regulatory defenses. Counsel should advise clients to monitor waiver-related litigation, evaluate potential market-distortion claims, and assess whether weakening scientific infrastructure erodes the standard of care in environmental review and agency rule-making.

Workplace Safety News This Week

During the week beginning November 9, 2025, a principal legal risk driver emerged: the marked diminution of regulatory oversight due to the ongoing federal funding impasse. The Occupational Safety and Health Administration (OSHA) website confirms that routine news releases and inspection updates have not been issued since October 1 owing to a lapse in appropriations. In practical terms, this operational pause creates an enforcement gap risk: employers may experience decreased federal inspection activity, but must remain fully accountable under the “general duty” clause of the Occupational Safety and Health Act of 1970 (OSH Act) for providing a workplace free from recognized hazards.

From a liability standpoint, companies cannot rely on a regulatory embargo as a defence; indeed, reduced governmental oversight may shift responsibility and risk onto employer-controlled compliance programmes. Until federal operations resume normalcy, risk mitigation should focus on internal audits, subcontractor oversight, documentation of hazard controls, and elevated monitoring of incident investigation protocols.

In sum: workplace-safety legal exposure is elevated in a low-visibility regulatory environment; firms should treat enforced inactivity not as relief but as a trigger for enhanced internal vigilance.

Senate Voting to End Shutdown

At midnight Sunday, the 9th, the Senate voted 60-40 to proceed to further votes to adopt a compromise worked out between Democrats and Republicans to end the longest government shutdown in the nation’s history.

Here are the core components of the compromise:

• Stopgap funding: A measure to fund the government through January 31, 2026.
• Future vote on health care: An agreement to hold a vote on extending Affordable Care Act health care subsidies by mid-December.
• Reversal of layoffs: Cancellation of all “reduction in force” notices (layoffs) that occurred during the shutdown.
• Reimbursement for states: Reimbursing states that used their own funds to keep federal programs running during the shutdown.
• Legislative branch funding: A separate bill that includes funding for the legislative branch, which will also include a ban on pay raises for lawmakers but an increase in their security.
• Other spending bills: Separate bills covering agriculture and military construction through most of 2026. 

Once it clears the Senate, it will have to return to the House for votes there, and then on to the President.

DG Transportation Issues

IHMM Global DG Transport Compliance Matrix (2025–2026)

United States

Developments

• There were no new final rules or Notices of Proposed Rulemaking (NPRM) this week from the PHMSA explicitly referencing ADR or the UN Model Regulations.

• However, an advisory by Ocean Network Express (Ningbo Port) dated 4 Nov 2025 reinstated a requirement for the submission of the UN 38.3 test report for lithium-battery shipments through that port. Although this is a port/terminal requirement (in China) rather than U.S., it has direct implications for U.S. exporters whose shipments transit that port.

Implications for U.S. stakeholders

Even without a U.S. domestic rule announcement this week, U.S. shippers/exporters must continue to monitor transit-node/port requirements (e.g., Ningbo) as such requirements can effectively set upstream compliance burdens. Given the U.S.’s alignment trend with UN Model Regulations, compliance risk arises from exporters failing to meet such transit/port-gate document requirements. Legal advisers should ensure contracts with carriers/forwarders cover such transit-document obligations and that SOPs reference UN 38.3 test-report submission for lithium batteries.

Europe

Developments

• Europe did not publish new amendments to ADR this week. The consolidated text of ADR 2025 (entered into force 1 Jan 2025) remains the operative standard.

• Industry commentary (e.g., a blog dated 17 Oct 2025) continues to highlight that, beyond 1 July 2025, full mandatory compliance with ADR 2025 is expected in most Contracting Parties.

Implications for European/ADR parties

Although no fresh legal text emerged this week, the focus remains on enforcement readiness post-transition-period. Legal counsel should advise that, for any cross-border road transport of DG in Europe, documentation, driver-training, transport unit marking and packaging must comply clearly with ADR 2025 amendments—any deficiency may increase liability in an incident. Proper audit trails of internal training, transport documents, vehicle certificates are now essential.

Asia

Developments

• The Ningbo Port advisory referenced above is particularly relevant to Asia: it mandates the UN 38.3 test-report submission for lithium-battery (Class 9) shipments effective immediately.

• While not a national regulation under ADR per se, this port-gate rule signals tightening cross-border DG controls in Asia, especially for lithium batteries and battery-powered equipment.

Implications for Asian/regional carriers & exporters

This week’s port advisory means that enterprises sending lithium-battery shipments via Asian ports must factor port-specific documentation requirements that exceed baseline ADR/UN rules. Legal/compliance teams should: (i) map transit ports and their special rules, (ii) ensure forwarders and shippers include transit-document obligations in contracts, (iii) audit that the correct format UN 38.3 test-report is submitted ahead of booking. Failing to comply may lead to cargo rejection, delays, or liability for downstream carriers.

Africa

Developments

• No new major public rule-making announcements were identified this week for African jurisdictions under ADR/UNECE frameworks.

Implications for Africa-based operations

Although silent this week, the absence of announcements should not reduce vigilance. Many African states are still implementing ADR/UNECE derived frameworks and may issue sudden local regulations or port/terminal rules that raise compliance burdens. Legal advisors should maintain up-to-date lists of national DG-transport implementing regulations, terminal mandates, and audit procedures.

Central & South America

Developments

• There were no new federal rule-making announcements this week in key Latin American jurisdictions (e.g., Brazil, Mexico) specifically referencing ADR or UN Model Regulations.

Implications for Latin-America operations

Given the global trend of ramping regulation (e.g., battery/vehicle/waste entries under ADR/UN Model Regs), Latin-American operators should assume that national regulation adoption is imminent. Legal/compliance teams should review local national DG-transport regulations for updates, and adjust internal training, contracts and documentation templates accordingly – even in the absence of this week’s formal text.

Cross-Jurisdictional Themes & Commentary

• Transit-node/port rule escalation: The Ningbo Port advisory underscores a shift toward transit/terminal-specific mandates (e.g., UN 38.3 test-report submission) that may go beyond treaty-level DG rules. Companies operating global supply-chains must monitor not only national law but also terminal/port/freight-forwarder acceptance criteria.

• Enforcement readiness post-transition: In Europe (ADR 2025) and globally for UN Model Regulations, transitional phases are closing. Even though no new amendment emerged this week, the operational standard of care continues to move upward. Legal risk arises when companies rely on legacy compliance regimes.

• Battery/lithium-ion equipment remains a focal point: The handling of lithium-battery powered vehicles, sodium-ion batteries, etc., continue to feature heavily in DG amendments (ADR 2025, UN Model Regs). This week’s port notice is symptomatic of that focus.

• Silent weeks don’t equal inactivity: The lack of formal rule-making announcements this week in many jurisdictions does not denote regulatory pause. Rather, many authorities continue to implement, audit, or issue guidance quietly—or impose operational/terminal-level requirements—making monitoring and contract review critical.

Legal Risk & Advice Points

1. Contractual drafting – Include provisions ensuring carriers/forwarders commit to meeting not just national DG regulation but also terminal/transit-node/document obligations (such as UN 38.3 test-report submission).

2. Audit/training – Confirm that staff (shippers, carriers, drivers) are trained to the latest version of DG regulations (e.g., ADR 2025) and that documentation/transport documents reflect the correct edition version.

3. Documentation – Ensure DG transport documentation includes up-to-date entries (UN numbers, shipping names, special provisions), especially for lithium-battery consignments and mixture packagings.

4. Port/terminal dependencies – Legal teams must map that transport doesn’t only transit domestic roads but may involve terminals and ports with stricter requirements (as seen with Ningbo Port). Checklist and contract terms should cover such dependencies.

5. Jurisdiction-by-jurisdiction monitoring – Maintain a regulatory-watch list for key jurisdictions (U.S., EU-27, China, India, Brazil, Mexico, UAE, South Africa, Australia) so that when a regulation is published the compliance team is ready to respond.

Conclusion

In the week of November 9, 2025, the regulatory landscape for dangerous goods transport did not produce sweeping new treaty amendments under ADR/UNECE; nonetheless, it showed critical operational developments—most notably terminal-level documentation mandates in Asia—and underscored the maturity of the global transition to heightened DG compliance (ADR 2025, battery entries, etc.). For legal advisors and compliance officers, the message remains: update your systems to the new baseline, monitor transit-node requirements, and ensure contracts and procedures reflect the current standard of care, not past editions of the regulations.

ICC Compliance Bulletin

This Month’s Spotlights:

• What’s New in IATA’s 13th Edition Battery Shipping Regulations unpacks the most important 2026 updates to battery transport rules. Learn about new classifications for battery-powered vehicles, stricter state of charge limits, digital tool upgrades, and practical guidance to stay compliant in a fast-changing regulatory environment.
• Top 10 OSHA Violations for 2025 breaks down the most frequently cited workplace safety standards, from fall protection to hazard communication. Discover which violations topped OSHA’s list this year and learn proactive steps to strengthen compliance, reduce risk, and build a safer work environment.
• Understanding Orange UN Numbered Panels explains when and how orange UN numbered panels should be used in the U.S., Canada, and internationally under regulations like 49 CFR, TDG, and IMDG. Learn how these panels serve as a compliant alternative to numbered placards for bulk shipments of dangerous goods.
• Health Canada Aligns GHS Enforcement with the OSHA Deadline outlines a risk-based approach allowing Canadian businesses more time to comply with WHMIS, in step with the U.S. OSHA’s 2027 deadline. This alignment helps companies using unified U.S./Canadian SDSs reduce regulatory friction and streamline compliance efforts across both jurisdictions.

IATA 2026 DGR Changes Announced

New IATA Dangerous Goods Regulations take effect January 1, 2026, with key updates for batteries, hybrid vehicles, and emerging energy tech. Get ahead of compliance requirements, and download the guide here.

Podcast Highlight: Trauma-Informed, Resilience-Oriented Leadership

In this excerpt from our podcast series, What It Means to Be a School Leader, Dr. Linda Henderson-Smith shares her perspective on trauma-informed leadership in schools: Listen here

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Resource Highlight: Returning to School After a Crisis

There is no one-size-fits-all approach to supporting students after a traumatic event. The information below contains lessons learned from research on previous school shootings. However, it’s most important to let students know you are there for them, however they need, and encourage them to talk. Learn more here.

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STOP School Violence Program FY2025 Funding Opportunity

The Bureau of Justice Assistance (BJA) has announced its STOP School Violence Program FY2025 Funding Opportunity to support initiatives that prevent and reduce school violence through training, threat assessment teams, and other safety strategies. A recording of the informational webinar on this grant is available on our website

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• FY25 Office of Justice Programs Community Based Violence Intervention and Prevention Initiative
• OJJDP FY25 Strategies To Support Children Exposed to Violence

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Additional School Safety Resources

• 11/19 – Enhancing School Safety Using Behavioral Threat Assessment
  Hosted by the Department of Homeland Security

Recent News from the European Chemicals Agency

• One hazardous chemical added to the Candidate List 

• Draft mapping of PFAS uses published 

• Consultation on harmonised classification and labelling 

• New proposals to harmonise classification and labelling 

• New IUCLID service release published 

• One Health. One Planet. Our Responsibility. 

• Watch the recording: Consultation on PFAS draft opinion – Guidance for respondents 

• Survey on nanomaterials used as or integrated into flame retardants 

• Biocides decisions on Union authorisations