To Reauthorize the Hazardous Materials Transportation Act Through Fiscal Year 19
To Reauthorize the Hazardous Materials Transportation Act Through Fiscal Year 19
Zehaz00
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III. A. First, the Class 9 designation now fails to convey meaningful information about the transport risks presented by such a range of materials. We are concerned that the United States is retreating from its commitment to the spirit of harmonizing hazardous materials transportation requirements by some of its recent additions to Class 9. If the United states wants to regulate other categories of materials as hazardous such as "oils" and "elevated temperature materials, " Congress should requ...ire DOT to use ORM (otherwise regulated materials) designations to distinguish such categories in domestic regulation until the United Nations accepts these categories of materials as Class 9 materials. III. B. Second, DOT has eliminated requirements to use the Class 9 placard for domestic shipments compounding the information gap problem. DOT claims the diversity of materials which now constitute Class 9 make placarding a useless exercise. Moreover, according to DOT, Class 9 materials are of such low risk that they do not deserve to be recognized by a placard in the same manner as Class 3 (flammable) materials, for example.
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