COVID-19 - Resources

Currie Associates’ Commitment to You. We at Currie Associates would like to extend our best wishes and thoughts to our clients, their families and the entire hazmat community during this difficult time. Responses to the COVID-19 outbreak are constantly changing and that has an obvious impact to all our operations as well as employees’ and their families’ lives. We are all in this together, and we want you to know that Currie Associates is here for you. Currie Associates Inc. has been designated as an essential business and we are well equipped with necessary resources to follow CDC guidelines of social distancing, respond to daily changes, and continue to operate our business to support your needs without interruption.

Where onsite training may not be practical, we remain prepared to provide training via webinar or through our library of online e-Learning courses.

If you are experiencing staffing shortages with your regulatory compliance or EHS employees during this time, we are here and available to support your needs. We can help with your DG transportation related questions, classification and product review, SDS review, and more.

We greatly appreciate your business and will continue to navigate these trying times together! If you have any questions, please do not hesitate to contact us via phone or email.

RESOURCES:

December 8, 2020: PHMSA Notice of Reinstatement and Extension of Enforcement Discretion for the Transport of Hand Sanitizers

October 30, 2020: Notice of Enforcement Policy for Hazardous Materials Training Requirements for Maritime Workers

September 28, 2020: Notice of Administrative Discretion and Guidance for Renewal of RIN Approvals During the COVID-19 Public Health Emergency

July 2020: COVID-19 Implications for EPA’s Enforcement and Compliance Assurance Program: Addendum on Termination. The EPA has issued an addendum to its Memorandum on COVID-19 Implications for EPA’s Enforcement and Compliance Assurance Program. The addendum states that August 31^st, 2020 as the termination date for the policy. Some states or regions may be subject to an earlier termination date depending on conditions of the area. The full EPA announcement can be found here.

July 2, 2020: PHMSA Notice of Extension of Enforcement Discretion for Cylinders Exceeding Periodic Testing Dates

June 24, 2020: PHMSA has extended the COVID-19 response provisions on FDA-approved hand sanitizers and the recurrent training deadline. Both temporary provisions will now expire October 31, 2020.

Notice of Extension of Temporary Policy for the Transport of Hand-Sanitizers

Notice of Extension of Enforcement Discretion Regarding Hazardous Materials Training Requirements

June 25, 2020: The UK Civil Aviation Authority (CAA) has issued an approval to allow UK operators of UK-registered aircraft to carry and use hand sanitiser in aircraft cabins. Those holding a UK Dangerous Goods approval, carrying replacement hand sanitiser (Alcohols, nos; Ethanol solution; or Isopropanol) in the cargo compartment must continue to do so in full compliance with the ICAO Technical Instructions. (June 25, 2020 – HCB eNewsletter)

June 19, 2020: PHMSA Safety Advisory for the Transportation of COVID-19 Diagnostic Samples. PHMSA plays a leading role in ensuring the safe transportation of hazardous materials in commerce throughout the United States. As a result of the ongoing Coronavirus Disease 2019 (COVID-19) public health emergency, certain shipments of COVID-19 diagnostic samples (e.g., nasal swabs, vials of sputum, and other related items) are classified as a Category B infectious substance (Division 6.2) hazardous material under the Hazardous Materials Regulations (HMR). Recent compliance inspections and found several instances of improperly marked or packaged diagnostic samples that were offered for transportation. In response, PHMSA is issuing this Safety Advisory Notice to provide information on the HMR related to offering and transporting these materials. Read more… View the Safety Advisory for more information. (June 19, 2020 – PHMSA)

USPS New Mailing Standards for COVID-19 related Category B Infectious Substances. The USPS has published a temporary final rule on new mailing standards for COVID-19 related Category B infectious substances on a temporary basis until the public health emergency (declared on March 13, 2020) is terminated.

Publication 52, Hazardous, Restricted, and Perishable Mail regulations, Packaging Instructions 6C have been revised to address the public health emergency and to support the distribution of diagnostic test kits using the mail. All shippers of COVID-19 related infectious substances Category B must obtain authorization from the Postal Service prior to mailing to ensure the diagnostic kits are properly packaged, marked, and labeled.

Please find additional information in the April 23, 2020 Postal Bulletin