Comments on Recently Issued U.S. DOT Letters of Interpretation

摘要

In PHMSA interpretation 08-0301 (see p. 34) issued to APL, Americas Region, PHMSA seeks to clarify the meaning of revised import responsibilities contained in HM-215I, in particular who is the initial US carrier in §171.22(f)(2) which states:rn"(2) After May 4, 2009, the shipper, directly or through the forwarding agent at the place of entry, must provide the initial U.S. carrier with the shipper's certification required by §172.204 of this subchapter, unless the shipment is otherwise excepted from the certification requirement. Except for shipments for which the certification requirement does not apply, a carrier may not accept a hazardous material for transportation unless provided a shipper's certification."