2 New PHMSA Hazmat Interpretations for August 2017

Posted on 9/11/2017 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.

Award-winning DOT Hazmat Training in Houston and Baton Rouge

Build the expertise and skills to keep your hazmat
shipments in full complWinner-Logo-Best-of-2017-Industry-Insights.jpgiance with new and changing 49 CFR, IATA DGR, and IMDG Code requirements. Join us in Houston on October 2—5 for complete multimodal hazmat training (49 CFR, IATA, + IMDG). In Baton Rouge, get training on the latest US DOT ground shipping regulations on September 28—29.

Find out why Lion Technology took home the title of Best Regulatory Compliance Training—USA in 2017 by Industry Insights Monthly.  Plus, take home resources and materials you can use to find fast answers to your shipping questions and get a full year of Lion Membership for ongoing compliance support. 

Tags: dangerous, DOT, goods, hazmat, hazmat shipping, PHMSA

Find a Post

Compliance Archives

Lion - Quotes

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms.

David Hertvik

Vice President

More thorough than a class I attended last year through another company.

Troy Yonkers

HSES Representative

The course is well thought out and organized in a way that leads to a clearer understanding of the total training.

David Baily

Hazmat Shipping Professional

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

The instructor was very very informative, helpful, understandable and pleasant. This course answered many questions I had, being new to this industry.

Frances Mona

Shipping Manager

Download Our Latest Whitepaper

Just starting out with shipping lithium batteries? The four fundamental concepts in this guide are the place to start.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.