PHMSA Response Letter

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Aug 15, 2006

Mr. Greg Dolan                 Reference No. 06-0171
Vice President, Communications and Policy
Methanol Institute
4100 North Fairfax Drive
Arlington, VA 22203

Dear Mr. Dolan:

This is in response to your July 17, 2006 letter on behalf of the Methanol Institute and 12 companies concerning your support for the commercialization of fuel cell technologies. In the letter, you encourage the Pipeline and Hazardous Materials Safety Administration (PHMSA) to incorporate requirements for transporting methanol fuel cells into the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

We will address harmonizing the requirements in the HMR for the transportation of methanol fuel cells with the standards adopted for the 14th Revised Edition of the UN Recommendations on the Transport of Dangerous Goods (UN Recommendations) in a notice of proposed rulemaking (NPRM) we plan to publish this summer under Docket HM-2151. We plan to consider incorporation of the provisions adopted in the international Civil Aviation Organization’s Technical Instructions for the Transport of Dangerous Goods by Air (ICAO TI) applicable to the carriage of portable electronic devices, such as laptop computers, cellular phones, and cameras powered by fuel cell systems containing flammable liquid, formic acid, and butane in the passenger cabin of an aircraft in a separate NPRM to be published later this year. Requirements adopted in the 15th Revised Edition of the UN Recommendations and in the 2009-2010 Edition of the ICAO TI will be addressed in a subsequent international harmonization NPRM. We encourage ‘u to review and submit comments on each of these NPRMs once they are issued.

Sincerely,

Robert A. Richard
Deputy Associate Administrator
Office of Hazardous Materials Safety

cc: Bruno Bich
     Chairman and Chief Executive Officer
     BIC Corporation

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