The Journal of HazMat Transportation's™ Exclusive Comments on U.S. DOT Letters of Interpretation of the HMR

摘要

Ed. Note: It is suggested that readers review PHMSA's letter prior to reading Mr. Lind's comments. That letter appears at the end of his comments. Links to respective sections referenced below may be found in the on-line version of this report under US DOT Letters of Interpretatation / Our Comments on Letters of Interpretation. In this request for a Letter of Interpretation (LOI) the LOGSA has asked for clarification of the selective testing variations. This facility acts as the testing facility for PHMSA enforcement testing as well as some R&D activities. Specifically in this case Variation 2 for combination packagings. The accompanying request to the LOI 21-0040 issued was not as complete as most which leads us to believe there is either an issue with testing for PHMSA enforcement, or they are preparing for a series of combination package testing and want to be prepared in the event of contention over methods. Both good reasons to seek an LOI for clarity, or as they say, granularity.