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PHMSA Outreach: Requirement to Pass the UN 6(d) Test Expanded

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As previously announced on this website on September 29, 2020, on May 11, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the U.S. Department of Transportation published Final Rule HM-215O implementing provisions to harmonize its Hazardous Materials Regulations (49 CFR parts 171 to 180) with various international standards.  This final rule included expansion of the requirement to pass the UN 6(d) Unconfined Package Test to four additional Explosive 1.4S entries:

  • UN0349 Articles, explosives, n.o.s.
  • UN0367 Fuzes, detonating
  • UN0384 Components, explosive train, n.o.s.
  • UN0481 Substances, explosive, n.o.s.

A copy of the HM-215O final rule can be downloaded from here: HM-215O/85FR27810-HM-215O

Not later than May 10, 2021, PHMSA approvals of products under these UN entries must:

  • Be updated by PHMSA to indicate compliance with the 6(d) requirement (such an update will be issued upon submission of appropriate, successful 6(d) test data to PHMSA), or
  • Be up-classed to something other than 1.4S (for example, 1.4D or 1.4B), or
  • Terminated.

IME recommends requests related to the above-listed actions be submitted to PHMSA as soon as possible and no later than April 10, 2021.  For more details, please see the compliance summary on IME’s website.(updated 5/6/2021)

Update (5/5/2021)

On May 4, 2021, PHMSA issued a "show cause" notification in the Federal Register advising holders of approvals for UN 0349, 0367, 0384, and/or 0481 to comply with the HM-215O requirement to pass the UN 6(d) test to retain 1.4S classification.  Failure to comply will result in termination of affected approvals.  For more, please see:

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