2 New PHMSA Hazmat Interpretations for August 2017

Posted on September 11,2017 by Roger Marks

Last month, the Pipeline and Hazardous Materials Safety Administration issued two hazmat interpretations that may be of interest to shippers, freight forwarders, and carriers.


Transporting Infectious Substances in an Ambulance  

Ambulance-3.jpgIn the first interpretation, dated August 15, PHMSA answers an inquiry regarding the 49 CFR exception for transporting infectious substances. When transporting a patient in an ambulance, when the patient is “contaminated” with Category A infectious substances, must the ambulance comply with the Hazardous Materials Regulations (HMR)?

The answer is no. The exception at 49 CFR 177.823(a) allows for transport of hazmat when necessary to protect life or property and allows for hazmat to be transported to a location where the material can be removed and disposed of safely. When transported under this provision, Category A infectious substances are excepted from HMR requirements.


Is Office Depot a “Cargo Facility”?

The second PHMSA hazmat interpretation concerns a retail store (Office Depot) that ships packages on behalf of customers via a major carrier. The question: Is the store required to display notices regarding hazmat air requirements and non-compliance penalties?

Office-Depot.jpgEven though the store does not accept hazardous materials packages by policy, the answer is yes.

Because the store is receiving cargo for air transport, the store must display the hazmat air requirements and penalties for violating the requirements, per 49 CFR 175.26.

The information that cargo facilities must post, in compliance with 49 CFR 175.26, includes:
 
  • A statement alerting customers to the applicability of the HMR to hazmat air shipments;
  • The maximum criminal penalty of 5 years prison time and a $250,000 fine; and
  • Examples of hazmat classes—“Hazardous materials include explosives, compressed gases, flammable liquids and solids, oxidizers, poisons, corrosives and radioactive materials.

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