Notice of Enforcement – HM-215

By October 13, 2020 49 CFR, IATA and ICAO, IMDG

Recently, PHMSA (Pipeline and Hazardous Materials Administration) issued a Notice of Enforcement Policy regarding international standards. PHMSA is anticipating that they will not have their harmonized rule, the HM-215 series published before the international standards become effective, January 1, 2021.

Part 171, subpart C of the 49 CFR allows for use of the International Civil Aviation Organization Technical Instructions on the Safe Transportation of Dangerous Goods by Air (ICAO Technical Instructions) and the International Maritime Dangerous Goods Code (IMDG Code) for preparation and offering of dangerous goods. However, the way Part 171 is written specifically mentions the publish date/amendment of the ICAO and IMDG.

Until PHMSA publishes their final HM-215 rule, they will allow the use of the 2021-2022 ICAO Technical instructions or Amendment 40-20 of the IMDG code, so long as all of relevant parts of the Hazardous Materials Regulations are met.

The Notice of Enforcement, published October 1 can be found here:

If you have any questions regarding this notice, or any other hazardous material questions, please contact us.

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Karrie Ishmael

Karrie Ishmael

Karrie started with the company in 1988 and has worked in a variety of capacities including customer service, sales, management, and marketing. In her current role as Regulatory Manager, she manages and supports ICC's efforts in supplying value-added services including training and SDS services to our clients. She is knowledgeable in a variety of regulations. She actively participates in a multitude of associations including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.