Miscellaneous Ammendments

AAR submits the following comment in response to the notice proposing miscellaneous amendments to the hazardous materials regulations, published on August 12, 2004. Current 49 C.F.R. sections 173.314 and 173.319 require shippers to notify AAR’s Bureau of Explosives (BOE) when shipments of certain compressed gases, in the case of section 173.314, or flammable cryogenic liquids, in the case of section 173.319, are not received by the consignee within twenty days of shipment. RSPA proposes to amend the sections to require notification of FRA instead of the BOE. RSPA’s stated rationale for making this change is that the “BOE no longer exists.” RSPA is in error. Not only does the BOE exist, but shippers continue to notify the BOE of shipments taking over twenty days, as required by today’s regulations. Nevertheless, AAR does not object if RSPA wishes to make the change for another reason.

AAR submits the following comment in response to the notice proposing miscellaneous amendments to the hazardous materials regulations, published on August 12, 2004. Current 49 C.F.R. sections 173.314 and 173.319 require shippers to notify AAR’s Bureau of Explosives (BOE) when shipments of certain compressed gases, in the case of section 173.314, or flammable cryogenic liquids, in the case of section 173.319, are not received by the consignee within twenty days of shipment. RSPA proposes to amend the sections to require notification of FRA instead of the BOE. RSPA’s stated rationale for making this change is that the “BOE no longer exists.” RSPA is in error. Not only does the BOE exist, but shippers continue to notify the BOE of shipments taking over twenty days, as required by today’s regulations. Nevertheless, AAR does not object if RSPA wishes to make the change for another reason.