PHMSA Issues Notice of Change on Termination of M-Number and R-Number Approvals with no Expiration Date
PHMSA has made a proposal to terminate previously approved M-numbers and R-numbers that were issued without an expiration date. Unless approval holders can either show why their approvals should not be terminated as provided in 49 CFR 107.713(c)(1) or apply for a modification of their approval in accordance with 49 CFR 107.705 prior to the effective date, their M-number may be considered expired. Modified approvals will conform to the Approvals and Permits Division’s standardized format in which all approvals have a 5-year expiration date.
What is an M-Number?
An “M-Number” or manufacturer number is issued by the D.O.T. to a manufacturer of packaging related to hazardous goods as a means of identification. This number is used in place of the manufacturer’s name and address as authorized in 49 CFR 178.503. In addition, an “R” number was a number previously given to companies that recondition their hazardous goods packaging, but PHMSA now uses M-numbers in their place. Often times the M-number is displayed on the outside of a package (like in the above picture). Manufacturer’s symbols can come in two formats. The first format lists the manufacturers sequentially by Identification Number (M#). The second format lists each state’s manufacturers alphabetically by city and company name. The identification number, the name and address, the status, and the date of the registration are provided in both formats.
What Does This Mean?
Any manufacturer that has an M-number that was issued before expiration dates were administered will have 1 year from publication of this notice to make contact with PHMSA. Affected manufacturers will have to demonstrate why their M-number should not be terminated per 49 CFR 107.713 (c) (1) or must apply for a modification of their approval in accordance with 49 CFR 107.705 to avoid termination. If manufacturers fail to comply and their M-number is terminated, they will be given 20 days to put a request in writing to PHMSA along with supporting documentation to reconsider.
Why Are They Making This Change?
PHMSA is concerned that holders of approvals issued without expiration dates may have stopped operations, or changed their names or principal places of business without notifying PHMSA. Requiring these holders to modify their approvals will require them to re-establish contact and communication with PHMSA as well as allow the D.O.T. to have the most up to date records of manufacturers.
