DG Advisor, LLC — Hazardous Materials Safety Interpretation

Page 1U.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 2Drakeford, 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#