June 8, 1999

Dockets Management System
U.S. Department of Transportation
Room PL 401
400 7th Street, S.W.
Washington, DC 20590

Re: RSPA-99-5019 (HM-229), "Hazardous Materials: Revisions to the Incident Reporting Requirements and the Detailed Hazardous Materials Incident Report DOT Form F 5800.1"

Dear Mr. Roberts:

HMAC is an international, non-profit, educational organization devoted to promoting safety in the domestic and international transportation and handling of hazardous materials, substances and wastes. HMAC represents shippers, carriers of all modes, container manufacturers and reconditioners, emergency response and waste clean-up companies, and a variety of other companies and trade associations involved in the field of hazardous materials transportation.

Although we do not have specific comments on Docket HM-229 at this time, we note that § 171.15(a) of the present regulations concerning notice of certain hazardous materials incidents states that

"... after each incident that occurs during the course of transportation (including loading, unloading and temporary storage)..." (italics ours)

We believe the term "temporary storage" should be reviewed after final action on HM-223 ("Applicability of the Hazardous Materials Regulations to Loading, Unloading and Storage") is complete to ensure the term is clearly defined and there is consistency between the two regulations.

HMAC appreciates the opportunity to submit this comment. If you should have any questions on the issue we have raised, please feel free to contact HMAC at 202-289-4550.

Sincerely,

Jonathan Collom
President