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USPS recently announced new packaging requirements for hazardous materials (HAZMAT) or dangerous goods (DG) sent through the mail. USPS regulates HAZMAT that flow through the US mail, and such requirements do not always align with the HAZMAT regulations (HMR) adopted by the Department of Transportation and the Pipeline and Hazardous Materials Safety Administration.

USPS has various publications about its restrictions on the mail, including Publication 52, titled “Hazardous, Restricted, and Perishable Mail.” USPS’s new rule adds to publication 52 a new section 131, requiring specific outer packaging for most HAZMAT or DG. The new section requires rigid outer packaging and requires that the outer packaging meet minimum burst test or edge crush test strength requirements. The specific strength requirements vary based on the weight of the overall package. Although several public comments regarding the change noted variability between this requirement and the HMR, which could make multimodal HAZMAT shipments more complex, USPS stated that the rule was necessary and “Large manufacturers and distributors should be well versed in handling complexities when they are preparing hazardous materials for transport as each mode of transport (e.g., air, rail, ground, vessel) has its own requirements.” Companies should ensure that any HAZMAT shipments meet the requirements of all applicable modes of transportation.

Tags: HAZMAT, USPS
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Photo of Amy Symonds Amy Symonds

Amy Symonds is an Environment and Natural Resources Group senior counsel in the firm’s Washington, D.C. office. Her practice primarily focuses on assisting clients with pesticide and chemical regulation and litigation matters. She also focuses on general environmental and administrative law issues.

In…

Amy Symonds is an Environment and Natural Resources Group senior counsel in the firm’s Washington, D.C. office. Her practice primarily focuses on assisting clients with pesticide and chemical regulation and litigation matters. She also focuses on general environmental and administrative law issues.

In her pesticide practice, Amy has assisted both task forces and individual companies by explaining complex state and federal regulatory requirements, drafting contracts for the transfer of pesticide registrations and data, and identifying and mitigating data protection concerns when submitting pesticide data to or relying upon pesticide data in foreign countries. She has represented both data submitters and follow-on registrants in arbitrations regarding data compensation claims involving pesticide data submissions under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Amy also defends pesticide companies in enforcement actions brought by the Environmental Protection Agency (EPA).

In her chemicals practice, Amy has assisted clients ranging from petrochemical companies and traditional chemical manufacturers to automobile and computer parts manufacturers. She has developed processes for her clients to identify and address applicable Toxic Substances Control Act (TSCA) requirements, and advised clients regarding their obligations to report under TSCA’s chemical data reporting rule in complex factual scenarios.

Amy has conducted audits for her clients to determine and perfect compliance with FIFRA, TSCA, and the Emergency Planning and Community Right-to-Know Act (EPCRA). She has also assisted clients with various matters arising under the Endangered Species Act, the Marine Mammal Protection Act, the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Animal Welfare Act, and the Federal Select Agent Program. Amy has worked with clients to address the release of documents under the Freedom of Information Act.

During law school, Amy was a member of the Order of the Coif and the George Washington Law Review. In 2014-2021 she was named a “Rising Star” by Washington, DC, Super Lawyers.

Prior to entering private practice, Amy assisted the general counsel of the U.S. Nuclear Regulatory Commission (NRC) in presenting policies regarding the protection of nuclear power plants against external threats. During her time at the NRC, she also advised the general counsel on communications with persons suspected of misuse of nuclear materials.

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