If you are looking for clarification on the regulations from the 49CFR, oftentimes it is a good idea to check the interpretation section of the PHMSA website. There have been many times when these interpretations have provided me with enough guidance to make an informed decision across various topics when shipping dangerous goods. In regards to the actual dangerous goods regulations, there are always changes on the horizon, and this now includes the interpretation section on the PHMSA website. PHMSA is now conducting an initiative to convert historical letters of interpretation related to the 49CFR that have been issued into a broadly applicable frequently asked questions (FAQs) section on its website.
What are Letters of Interpretation and What does This Mean?
PHMSA interpretations are written explanations of the 49CFR hazardous materials regulations from various members of the PHMSA. The interpretations come in the form of letters that originate from various dangerous goods professionals asking specific questions about the regulations and the questions in the letters are answered by members of PHMSA. They are to be used only as a form of guidance when following the regulations. This previous blog I wrote provides more specifics and examples.
As mentioned, PHMSA seeks to make some changes to its letter of Interpretation section on their website. Ultimately, PHMSA’s goal is to create a repository of frequently asked questions that derive from common letters of interpretations and hopes to eliminate the need for recurring requests of interpretations that involve repeated topics. In addition, PHMSA is asking the public for comments on this initiative to help move it forward. If you are interested in providing comments on the initiative, you are invited to submit your input on the prioritization of future sets of FAQs on or before May 23, 2022. See the Federal Register Notice below for more details on how to make comments and to read the introduction to the initiative and its objectives: Click here.
And as always feel free to contact ICC Compliance Center for products, services, and training to assist you in shipping your dangerous goods.
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