ILMA Compoundings - April 2021 - 43

Figure 2: Proposed OHMS Organizational Structure
PHH-2 (Offices of Associate Administrator and Deputy Associate Administrators)

PHH2

Standards
(from PHH-10)

*	Elimination of the existing Approvals and
Permits division.
*	Creation of a Research branch under the
Operations Systems division.
*	Combining field support and program management functions in one branch located in
the Operation Systems division.
*	Creating a new program analysis and management function, reporting to the deputy
associate administrator for Field Operations.
One of the most important features of the
reorganization, which Schoonover hopes to have
completed by the end of the first quarter of 2021,
is eliminating the Approvals and Special Permits
division and moving its key functions to the
Standards division, currently overseen by Shane Kelley. The
Standards division is responsible for, among other things,
developing new and overseeing implementation of existing
hazmat transportation regulations and related guidance and
providing input into " ... policies, strategies and procedures " for international harmonization activities.
Kelley is a seasoned regulator who possesses a deep
knowledge of both domestic and international regulatory
processes, having previously served as the agency's international standards coordinator. His background will come in
handy because the Approvals and Special Permits division
has historically been one of the busiest in the OHMS.
On average, the PHMSA issues about 1,700 special
permits and 9,000 approvals annually to businesses and
government agencies throughout the U.S. Special permits
authorize companies to perform a hazmat transportation
activity outside of existing regulations, whereas approvals
authorize the transportation of certain hazardous materials
(e.g., explosives) or the performance of a designated hazmat
function (e.g., cylinder re-tester). Special permits and
approvals are particularly crucial in emergency situations

Standards
Development

International
Programs

Budget and
Administrative
Services

Science and
Engineering

External
Engagement

Data and
Analysis

(from PHH-20)

(from PHH-50)

(from PHH-60)

Sciences

(from PHH-60)

Promotion
Programs
(Name Change?)

Risk Data and
Program
Management
(including PHH-40)

Data Operations
and Registration

Regulatory
Review and
Reinvention

Engineering

Special Permits

Pressure Vessel
Approvals

Research and
Development

(from PHH-30)

(from PHH-60)

(from PHH-30)

Grants
(Registration to
PHH-60)

(Registration from
PHH-50)

Energetic
Materials
(from PHH-30)

Radioactive
Materials
(R&D Removed)

like the aftermath of a hurricane, when vehicles carrying
needed hazardous materials, such as propane, must be
moved quickly to remote locations.
Another important aspect of the reorganization is the
creation of a research branch under a new Operations Systems division, which is expected to be managed by Yolanda
Braxton. The OHMS has steadily increased spending on
research programs in recent years and is authorized to spend
more than $7 million on R&D in fiscal year 2021. The new
branch is likely to play a more important role in a range of
regulatory activities in the years ahead.
In conclusion, although governmental reorganizations
are rarely front-page news, for the thousands of companies
across the U.S. that manufacture, package and transport
hazardous materials, significant changes to the administrative structure of the lead national agency that regulates these
activities are well worth paying attention to today and in the
months ahead.
Rankin is president of the Reusable Industrial
Packaging Association.

43
ILMA Compoundings - April 2021

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