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Generally, once a year, the Pipeline and Hazardous Materials Safety Administration (PHMSA) publish a final rule called HM-215. 

This final rule’s purpose is to align the 49 CFR regulations with the international regulations including International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) and the International Maritime Organization, International Maritime Dangerous Goods Code (IMDG Code). 

The 49 CFR Part 171.7 allows offerors and carriers to use the international regulations when preparing their shipments intended to ultimately ship via air or ocean.  

When the final rule (HM-215) is delayed, it causes shipper’s concern, because the 49 CFR regulations specifically identify with the versions of said regulations. The current edition of the 49 CFR references the 2019-2020 ICAO regulations, and amendment 39-18 of the IMDG code, which are now out-of-date. 

Luckily, PHMSA understands that this dis-harmonization will cause concern for offerors and carriers, thus published a “NOTICE OF ENFORCEMENT POLY REGARDING INTERNATIONAL STANDARDS”. 

This notice allows offerors and carriers to use the most current regulations (2021-2022 ICAO and 40-20 IMDG code) when preparing their shipments for international destinations. 

A copy of this notice can be found here.

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US 49 CFR Publications

ICAO Technical Instructions, 2021-2022 Edition, English

IMDG Supplement, Amendment 40-20, 2020 Edition, English
Karrie Ishmael, CDGP

Karrie Ishmael has been with ICC since 1988. She has contributed to ICC's growth in various capacities, including customer service, sales, and marketing. In her current role as ICC's Senior Regulatory Expert and SDS author, Karrie conducts hazardous materials training classes in 49 CFR, IATA, IMDG, TDG along with OSHA and WHMIS hazard communication courses. When not training, she writes safety data sheets for customers to comply with North American and European requirements. She actively participates in many associations, including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.

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