ARA Signs Letter to PHMSA Requesting Withdrawal of Interpretation Letter

ARA signs a letter to Dr. El-Sibaie, associated administrator for Hazardous Materials Safety of the Pipeline and Hazardous Materials Safety Administration (PHSMA), part of the U.S. Department of Transportation. This letter requests the withdrawal of a letter of interpretation issued by PHMSA to Andrew N. Romach of AECOM on December 11, 2015. The letter was issued in response to a question from Mr. Romach about a packaging that, when filled, would have a maximum net mass greater than 400 kg (882 lbs.) and a maximum capacity less than 450 L (119 gallons). Under the current definitions of nonbulk and bulk packaging found in §171.8 the filled package would meet neither definition. The interpretive letter does not merely seek to explain a rule, it would change the existing rule.

READ MORE