Appeals to Docket No. HM-240 Final Rule Filed

摘要

A number of organizations filed appeals with the U.S. DOT on several provisions of the final, self-executing final rule, HM-240. All appellants took issue with the revised definition of "hazmat employer", several raised issues and sought reconsideration of the provisions pertaining to the continued acceptability of "DOT-E" markings on packagings as an alternative to marking of the corresponding DOT special permit ("DOT-SP") number. And two petitioners requested that the final rule be withdrawn and reissued as a notice of proposed rulemaking (NPRM) subject to normal opportunity for public comment. Questions were raised as to whether shipping papers were required to be retained for two years beginning from the date the Act was signed (August 10,2005), or from the effective date of the Docket No. HM-240 final rule. DOT has issued guidance on this matter which is discussed in Mr. Altemos' presentation.