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 Issues Memorandum – EPA – Updated Definition of Waters of the United States

On November 17, 2025, the U.S. Environmental Protection Agency and the Department of the Army (“the agencies”) announced the signing of a proposed rule to revise the definition of “waters of the United States.” This proposal implements the Supreme Court’s decision in Sackett v. EPA. The proposed rule will play a key role in EPA’s Powering the Great American Comeback initiative by protecting water resources, strengthening cooperative federalism, and supporting American industry, energy producers, the technology sector, farmers, ranchers, developers, businesses, and landowners.

In developing the proposed rule, EPA and the Army reviewed and considered the extensive feedback and recommendations the agencies received from States, Tribes, local governments, and stakeholders throughout consultations and the pre-proposal recommendations docket and listening sessions.

Read more here.

PFAS Reporting Rule Update for CHMMs & CHMPs

Deadline for Comment:  December 15, 2025

Federal Register

Risk Matrix for CHMM/CMHP and 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 is preparing comments to submit in response to this proposed rulemaking, and we will provide updates, tools, and training to support our certificants’ leadership in PFAS management.

IHMM – Workplace EHS Coalition Supports OSHA/NIOSH Funding

IHMM, and the Workplace EHS Coalition of which IHMM is a part, is writing to Congressional appropriators in support of funding OSHA and NIOSH, following up on our call for funding those organizations first made last May. With the shutdown over and Congress now back, we have prepared a letter to key House and Senate appropriations subcommittee leaders supporting robust funding levels for OSHA and NIOSH in any full-year FY2026 spending deal.

Fall 2025 Letter to Congress OSHA/NIOSH

The Workplace EHS Coalition (formerly known as the Intersociety Forum) is a coalition of organizations, including ASSP, dedicated to safeguarding worker safety and health and promoting the fact that safety practices create a strategic advantage that powers enduring business success while fostering innovation and protecting workers.

Despite advancements, workplace injury and fatality rates remain stagnant. By adopting proactive, risk-based safety strategies, businesses can unlock greater productivity, reduce costs, and strengthen their global competitiveness. The Workplace EHS Coalition urges today’s business leaders and policymakers to prioritize occupational EHS as a foundation of economic competitiveness. Adopting this approach will position the U.S. as a global leader in safety, innovation and workforce well-being, enabling workers and businesses to thrive.

Environmental News for This Week

During this week, the EPA, in conjunction with the U.S. Army Corps of Engineers, announced a proposed rule to significantly narrow the scope of federal jurisdiction under the Clean Water Act (“CWA”) by redefining the term Waters of the United States (WOTUS). Under the proposal, only relatively permanent water bodies (such as lakes, rivers, streams) and wetlands with direct surface connections to those bodies would qualify for federal protection.

Environmental groups are raising immediate alarms, warning that the rollback may reduce protections against flooding, impair wildlife habitats, and undermine water-quality safeguards tied to climate resilience.  From a legal and regulatory perspective, this proposed rule raises several key implications:

• For regulated entities, potential reduction in permitting obligations and federal oversight, but also increased state-by-state fragmentation and litigation risk from affected stakeholders.

• For credentialing bodies and organizations (such as IHMM) providing advisory or compliance services in environmental management, increased need to monitor shifting jurisdictional boundaries and state/federal interplay.

• For accreditation and regulatory exposure, the narrowing of “waters” may affect how environmental impact assessments, wetlands mitigation, and hydrologic-connectivity analyses are defensibly documented under the CWA and associated state programs.

In conclusion, the week’s developments signal a notable regulatory pivot in federal water-resource jurisdiction. Stakeholders should prepare for substantive rule-making, comment-period exposure, potential litigation, and downstream compliance complexity.

Ohio Supreme Court Says Courts Must Not Defer to the Industrial Commission 

The Ohio Supreme Court ruled on Oct. 16, 2025, that state courts should not defer to the Ohio Industrial Commission’s interpretations of Ohio’s safety laws or administrative rules when reviewing whether an employer violated them. The ruling in State ex rel. Berry v. Indus. Commission came after a worker appealed a commission ruling that he was not entitled to a Violation of Specific Safety Requirement (VSSR) award.

What’s the background?
Administrative law judges in the Ohio Industrial Commission hear appeals of Ohio Bureau of Workers’ Compensation (BWC) decisions. The Commission has exclusive and final jurisdiction to determine whether an injury, disease, or death resulted from an employer’s failure to comply with any specific safety requirement. Ohio employees may be entitled to VSSR awards when a workplace injury results from an employer’s violation of a safety requirement.

Read more here.

Workplace Safety News This Week

During this week, a key regulatory development warrants immediate attention: OSHA reported receipt of approximately 50,000 public comments on its proposed Heat Injury and Illness Prevention rule. IHMM was one of those commenters. This rule, under the title “Heat Stress in Outdoor and Indoor Work Settings,” would require employers to implement specific controls (e.g., water, shaded rest areas) once work-site heat indices reach defined thresholds. Many employers and trade associations argue a rigid national standard may be unworkable across diverse industries.
From a legal-risk and compliance perspective:

• Employers should anticipate a final rule timeline and begin gap-analysis of current heat-illness prevention programs.

• The comment volume signals that OSHA may impose broader enforcement tools or use the General Duty Clause to address heat hazards.

• Preparatory steps now may mitigate future citations or liability arising from heat‐related injuries.

In sum: The OSHA rule-making on heat stress is advancing into its next phase. Employers, especially those with outdoor or high-temperature indoor operations (construction, warehousing, manufacturing, agriculture), must evaluate their readiness and update safety programs accordingly.

DG Transportation Issues

IHMM Global DG Transport Compliance Matrix (2025–2026)

IHMM Certificant Compliance Checklist

For the week of November 24, 2025, the law of dangerous goods (“DG”) transport is not marked by a new headline-grabbing treaty, but by a set of quiet but important procedural and enforcement shifts under UNECE/UN auspices and in key national systems. What follows is a region-by-region analysis, written as counsel, of the developments most relevant to IHMM certificants and other DG professionals.

I. Global / UNECE: UN Model Regulations and ADR Architecture

A. UN Sub-Committee of Experts on the Transport of Dangerous Goods (UN-SCETDG-67)

On 24 November 2025, the 67th session of the UN Sub-Committee of Experts on the Transport of Dangerous Goods convenes in Geneva (24 November–3 December 2025).

This Sub-Committee is the body that drafts and updates the UN Model Regulations (the “Orange Book”), which in turn form the technical backbone of:

• ADR (road),

• RID (rail),

• ADN (inland waterways),

• and the maritime/air codes (IMDG, ICAO TIs).

Multiple informal documents (INF) dated mid-November have been filed in advance of this session. Their contents are not yet publicly accessible in detail due to UNECE hosting restrictions, but procedurally, this session will:

• Consider amendments that will become the 24th revised edition of the UN Model Regulations, building on the Committee’s decision of December 2024.

• Set the trajectory for the next full cycle of ADR, RID and ADN amendments.

For practitioners, the legal point is this: any change adopted in Geneva over the next ten days will cascade—with a typical lag of 2–3 years—into ADR 2027 and into national DG transport law across Europe, parts of Asia, Africa, and the Americas.

B. ADR Certificates and Multilateral Agreement M363

UNECE’s DG portal highlights two specific ADR-related items posted 20–21 November 2025:

• “ADR Driver training certificates: Uzbekistan (update)” – UNECE has uploaded updated models of ADR driver training certificates for Uzbekistan, noting that the models in use since 8 October 2020 have been revised as of November 2025.

• “ADR Multilateral agreements: Sweden signed M363” – Sweden has joined Multilateral Agreement M363, an ADR instrument allowing Contracting Parties to deviate jointly from certain ADR provisions under controlled conditions.

These actions are not new “laws,” but they are formally notified treaty practice:

• The Uzbekistan update confirms that its ADR driver certificates comply with ADR 8.2.2.8.5 requirements for format and content, which matters for roadside recognition and mutual acceptance.

• Sweden’s accession to M363 extends the geographical coverage of that derogation, which logistics counsel must consider when routing ADR consignments through or out of Sweden.

II. United States: PHMSA’s Data-Driven Enforcement Framework

The most concrete national-level development this week comes from the United States.

On 20 November 2025, PHMSA issued a press release titled “PHMSA Implements New Data-Driven Framework for Hazmat Transportation Inspection and Enforcement Standards.”

The release announces:

• A first-of-its-kind memorandum within the Office of Hazardous Materials Safety (OHMS) that sets data-driven priorities for outreach, inspection and enforcement.

• An explicit focus on high-risk DG actors, including:

  • General hazmat shippers,

  • Cylinder manufacturers and requalifiers,

  • Drum manufacturers and recertifiers,

  • Companies with prior major violations,

  • Lithium-battery shippers, and

  • Undeclared hazmat shippers operating via e-commerce platforms.

Legally, this does not immediately amend 49 C.F.R. Parts 171–180. It is instead an enforcement-policy instrument that will:

• Shape how existing DG rules are applied, which entities are inspected, and where civil penalties are concentrated;

• Provide regulated parties with an arguable basis to claim predictability and equal treatment, as the memo publicly states the criteria for PHMSA’s focus; and

• Increase the practical risk profile for shippers of cylinders, drums, and lithium batteries, and for any entity whose hazmat shipments via e-commerce have been under-declared or misdeclared.

For IHMM certificants operating in or into the U.S. system, this week’s development means that compliance failures in these priority areas now carry heightened enforcement salience even without a change in the underlying Hazardous Materials Regulations.

III. Europe: ADR 2025 Consolidation and EU Harmonisation

A. ADR 2025 and EU Delegated Directive 2025/1801

At the European level, the big legal changes preceded this week but continue to bite operationally:

• ADR 2025 (ECE/TRANS/352) entered into force on 1 January 2025 and became mandatory from 1 July 2025, with key technical changes including new UN entries and asbestos-related provisions.

• Delegated Directive (EU) 2025/1801, in force since 2 November 2025, introduces new requirements for the labelling of dangerous goods in EU road transport, described by practitioners as “one of the most important amendments to European dangerous goods legislation in recent years,” tightening responsibility allocation and controls.

During the week of November 24, no additional EU-level legislative texts have been adopted; however, Member States are now in the process of transposing Directive 2025/1801 into national law, and operators are adjusting documentation and labelling practices accordingly.

B. ADR Working Party (WP.15) and RID Meetings

Earlier in November, the 118th session of WP.15 (Working Party on the Transport of Dangerous Goods) and RID-related meetings concluded in Geneva, setting the groundwork for the next ADR and RID amendment cycle.

The week of November 24 therefore marks a transition point:

• Europe has fully moved into the ADR 2025 regime;

• The EU is layering 2025/1801 on top of ADR to harmonise road enforcement and labelling;

• And UNECE/UN-SCETDG-67 (see Section I) begins work on future amendments that will eventually become ADR 2027.

IV. Asia and Oceania: Global Framework Meets Regional Practice

No major new DG transport statute or rule specific to the week of November 24 has been identified for China, India, or other Asian states. Existing 2024-2025 updates—such as China’s adoption of new GB standards aligned with UN Model Regulations—remain the dominant changes but are not new this week.

However, two global developments are particularly relevant for Asian carriers and shippers:

• The UN-SCETDG-67 session in Geneva (Section I) is the formal venue through which Asian states influence the next UN Model Regulations; and

• The International Air Transport Association (IATA) has already announced significant DG changes for the 2026 DGR and the new Battery Shipping Regulations (BSR), with battery-related updates described as “dominating” the 2026 manuals.

For Asia-Pacific operators, the legal takeaway this week is anticipatory:

• The regulatory direction of travel is toward stricter, more detailed lithium-battery, packaging and documentation requirements, which will be finalized through the UN and ICAO mechanisms now in session or imminent.

V. Africa: ADR/UN as De Facto Standard, Limited New Text

For Africa, there is no evidence of a major DG-specific statute or regulation being adopted this week. Many African states rely on:

• National road-traffic and hazardous-substance laws,

• Selective adoption of UN Model Regulations and ADR principles, and

• Mode-specific rules issued by civil aviation and port authorities.

In practical terms, this week’s developments that matter to African DG transport are:

• The global UN-SCETDG-67 session, which shapes the Model Regulations these states look to; and

• The shift in U.S. and EU enforcement practices, which influences expectations for exporters shipping DG into those markets.

VI. Central & South America: Colombian Registry Effective Date Approaches

In Central and South America, the most directly time-linked development is not a new publication this week, but an approaching effective date:

• Colombia’s Resolution No. 20243040058015 (28 November 2024) establishes a registry of information for the transport of dangerous goods, with certain obligations coming into force from 30 November 2025.

As the week of November 24, 2025 begins, DG carriers and shippers in and through Colombia are:

• Within days of the registry’s entry into force, and

• Under a legal obligation to ensure that their DG operations are properly registered and traceable under the new system.

Elsewhere in the region (e.g., Brazil, Mexico, MERCOSUR states), the key DG transport instruments remain earlier 2024–2025 road and multimodal regulations aligned with UN and MERCOSUR DG frameworks, with no new Central/South American DG law visibly promulgated this week.

VII. Overall Legal Assessment for the Week of November 24

From a legal-risk perspective, three themes dominate this week’s DG transport landscape under ADR/UNECE auspices:

1. Global Norm-Setting in Geneva – The opening of UN-SCETDG-67 (24 Nov–3 Dec 2025) marks the beginning of the next amendment cycle for the UN Model Regulations, which will, in due course, recalibrate ADR, RID, ADN, IMDG and ICAO TI obligations worldwide.

2. Enforcement, Not Just Text, in the United States – PHMSA’s data-driven inspection and enforcement framework is a legal development in its own right: it changes the probability and focus of enforcement under existing rules, especially for cylinders, drums, lithium batteries, and undeclared hazmat via e-commerce channels.

3. Consolidation of ADR 2025 and EU Directive 2025/1801 in Europe – While no new ADR treaty text is adopted this week, ADR 2025 is now fully effective and being operationalised alongside Delegated Directive 2025/1801, which tightens EU-level DG labelling and responsibility frameworks.

Add to these the Uzbekistan ADR certificate update, Sweden’s signature of M363, and the imminent Colombian registry, and the legal picture for this week is clear: the structure of DG law is being refined and enforced more aggressively rather than radically rewritten.

Anonymous Reporting Systems

In this excerpt from our podcast series, Understanding Firearm-Related Injury and School Violence, Dr. Libby Messman explains key policies and research findings in violence prevention:

We need to understand what aspects of anonymous reporting systems are effective and what schools need in order to support students’ and teachers’ usage of these systems. Learn more here.

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School Safety Communications Planning Guide

As a school safety leader, you may be faced with widespread misinformation and polarized public opinions. These often leave your local school boards, administrators, teachers, and parents with mixed messages that make it difficult to discern the truth. According to a 2018 MIT Sloan study, false information is 70% more likely to be retweeted than the truth, causing it to reach more people faster than the truth.

You can help prevent incorrect information sharing and create a positive school climate by initiating preemptive conversations about misinformation and disinformation. Students and families are vulnerable to these types of incorrect information, so it is important to discuss these issues in your school and the community.

One way to be prepared to respond appropriately to incorrect information is to create a crisis response communications plan. You can use preplanned and scripted messages to prevent or stop the spread of inaccuracies on social media platforms.  Learn More

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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

• Four substances recommended for REACH authorisation
• Consultations on harmonised classification and labelling
• New intention and proposal to harmonise classification and labelling
• Annual fees for Union authorisations in R4BP 3
• List of biocides suppliers updated
• Science seminar: Protecting workers from reproductive hazards
• ECHA CHEM webinar: material available
• Contract research organisation days: meeting summary published
• Biocides decisions