The Journal of HazMat Transportation's™ Exclusive Comments on Current U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations

摘要

This letter raises an old issue that dates back to the days of 1990 when PHMSA (then the Research and Special Programs Administration [RSPA]) was first implementing the UN performance packaging requirements through docket HM-181. As PHMSA's (then RSPA) International Standards Coordinator at that time, I can still remember discussions on this topic in Washington with the then Chairman of the UN Committee of Experts on the Transport of Dangerous Goods. The issue was then and still remains (based on this new request), "Will PHMSA allow the USA mark on packagings manufactured outside the US?" RSPA's key consideration in 1990 was to maintain the worldwide reputation of packagings bearing the "USA" mark. To do otherwise could potentially frustrate US transport of dangerous goods throughout the world.