# DG Advisor, LLC — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 14-0097
- **title:** DG Advisor, LLC — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2014-05-28
- **effective on:** Not available
- **summary:** 14-0097 response to DG Advisor, LLC concerning 173.62.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-14-0097.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-14-0097.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-14-0097
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140097.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590
MAY 2 8 2014
Mr. Ben Barrett
DG Advisor, LLC
Ref. No.: 14-0097
Dear Mr. Barrett:
This is in response to your email dated May 19, 2014, requesting clarification of the
Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to recent removal of
Packing Instruction US 1 from § 173.62. You ask whether this action was intentional.
Due to an editorial error, § 173.62 Packing Instruction US 1 was inadvertently deleted in a
final rule published on the January 7, 2013 under Docket No. PHMSA-2012-0027 [78 FR
988] (HM-215L). PHMSA is working with the Government Printing Office to correct the
error and reinstate Packing Instruction US 1. During the interim, § 17'}.62 Packing
Instruction US 1 in effect on December 31, 2012, may continue to be used.
I trust this information is helpful. If you have further questions, please do not hesitate to
contact this office.
Sincerely,
-~'~Q.-r
Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division

<<<PAGE 2>>>

Drakeford, Carolyn (PHMSA)
From:
Sent:
To:
Cc:
Subject:
Wiener, Aaron (PHMSA)
Tuesday, May 20, 2014 9:34AM
Drakeford, Carolyn (PHMSA)
Dodd, Alice (PHMSA); Goodall, Shante CTR (PHMSA)
New lnterp
l>ad-l-"~ j 1h ')hvch'ovts
l L{-0091
From: Ben Barrett [mailto:ben.barrett@dgadvisor.com]
Sent: Monday, May 19, 2014 11:09 AM
To: Betts, Charles (PHMSA)
Subject: Packing Instruction US 1
Dear Charles,
I heard that this packing instruction for perforating guns in the US was deleted, and I do not see it in the online
CFR. It is the basis for the operation ofthe oil well industry. Are you aware ofthis, and was it intentional or is it
an error that will be fixed? What should the industry be told during the interim?
I was in the office a few weeks back, sorry to have missed you. You might give me a call if you have time.
Best Regards,
Ben
Ben Barrett, PE, Consultant
DG Advisor, LLC
Explosives Regulations Experts
Mobile & Text: +1816-853-3508
Email: ben.barrett@dgadvisor.com
1
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