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PHMSA Issues Two Hazmat Container Interpretations

Posted on 2/26/2016 by Roger Marks

This year, PHMSA has responded to a number of requests-for-interpretation from industry professionals seeking clarity on specific parts of the Hazardous Materials Regulations at 49 CFR 171–181. These interpretations are a great representation of the way hazardous materials regulations intersect with the realities of managing and shipping hazmat in the real world.

“Old” Special Permit Numbers on Hazmat Containers

Following an Executive Order from the President, PHMSA has begun to incorporate longstanding hazmat special permits into the text of its Hazardous Materials Regulations (HMR). Doing so allows hazmat shippers access to the reliefs and allowances provided by special permits without applying to become a party to the permit.
PHMSA hazmat special permit number on hazmat package
Because each hazmat special permit has anumber, and hazmat shipments prepared in accordance with the terms of a special permit must feature that number, the question must be asked: What should a shipper do if a special permit that is used—for which the number permanently appears on containers like cylinders or intermediate bulk containers (IBCs)—gets incorporated into the HMR and therefore no longer needs a “special” number?

In an interpretation letter dated January 8, 2015, PHMSA clarified its position on “old” special permit numbers appearing on hazmat containers. In short, a container permanently marked with a special permit number may be used until the end of its lifecycle, even if the special permit is incorporated into the HMR.

How to Condemn Hazmat Cylinders

In its standards for pressurized hazmat cylinders at 49 CFR 180.205(i), DOT PHMSA’s Hazardous Materials Regulations (HMR) provide specific criteria for determining when a cylinder may no longer be used and must be condemned. As part of condemning a hazmat cylinder, the HMR states that the owner must render it “incapable of holding pressure.”

In its letter of interpretation, PHMSA makes it clear that removing or destroying the service valve on a cylinder is not an effective way to render it “incapable of holding pressure.” Instead, PHMSA suggests cylinder owners drill holes in the empty cylinder to condemn it.

49 CFR Hazmat Training You Can Trust 

Be confident you and your shipping team are prepared for all DOT's latest hazmat regulations, including the newly finalized Hazmat Special Permit "Mega Rule.” Lion's expert instructors will cover the latest rules you must know at the interactive Hazardous Materials Transportation Certification Workshop, presented in cities nationwide. Click the link to discover how you can prepare your team for full compliance with the HMR.

US DOT requires training for all “hazmat employees” once every three years and when rules change [49 CFR 172.704] 

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