costhalogo2010                                                               MEMO

 


Dangerous Goods Transportation Compliance

To: COSTHA Member
From: Lara Currie, Administrator
Re: COSTHA Petition Special Permit 9275
Date: January 5, 2012

 

The US DOT PHMSA has assigned a petition number (P-1585) to COSTHA’s June 14, 2011 petition to incorporate the long standing regulatory exceptions for small quantities of products containing ethyl alcohol (SP9275). From here, PHMSA will publish a notice of proposed rulemaking which will allow for additional comments.  There is no timeframe for when they will publish the NPRM.

“DOT-SP9275 was initially granted in 1986 to authorize the transportation in commerce of certain limited quantities of liquids and solids containing ethyl alcohol, primarily consumer products such as cosmetics, beverages, foods, medicines, medical screening solutions and concentrates used therein.  The transportation was exempt from the HMR except as specified in the special permit (including packaging requirements), and the SP was reissued by the agency several times over the ensuring 25 years.

Because of the longstanding history of safe transportation under DOT-SP9275, COSTHA petitioned PHMSA on June 14, 2011 for a rulemaking to incorporate the terms of the special permit into the HMR. As part  of the petition COSTHA appended the results of tests conducted by TEN-E Packaging Services, Inc. on the types of packages used in DOT-SP9275.” (Petition to Modify DOT Special Permit 9275, Richard P. Schweitzer, COSTHA General Counsel)

COSTHA has identified this project as a key issues in our effort to have DOT evaluate regulations and Realign them with the Risk posed in transport.

Click here for additional information on the petition and other projects that COSTHA has undertaken regarding this long standing special permit.

 

COSTHA

7803 Hill House Court

Fairfax Station, VA 22039

Phone: 703/451-4031  Fax: 703/451-4207
mail@costha.com  www.costha.com