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ARTICLE · 23 JULY 2012

PHMSA Seeks Comment On Advanced Notice Of Rulemaking On "Reverse Logistics"

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On July 5, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation published an Advanced Notice of Proposed Rulemaking (ANPRM) "to identify ways to reduce the regulatory burden for persons who ship consumer products containing hazardous materials in the "reverse logistics" supply chain."

United StatesInternational Law
Seth Goldberg
Seth Goldberg
Bizunesh “Biz” Scott
Bizunesh “Biz” Scott

On July 5, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation published an Advanced Notice of Proposed Rulemaking (ANPRM) "to identify ways to reduce the regulatory burden for persons who ship consumer products containing hazardous materials in the "reverse logistics" supply chain."1 Following collection of information requested in this ANPRM, PHMSA anticipates crafting a final rule that would "simplify the regulations for reverse logistics shipments and provide avenue means for regulatory compliance that maintains transportation safety."2

Reverse logistics "pertains to the safe return of goods from the marketplace to the original vendor, manufacturer, or supplier" and, in essence, is the supply chain in reverse.  According to the current Hazardous Materials Regulations (see Title 49 of CFR), consumer products no longer useful in the retail market, such as used batteries, are considered "fully regulated" and,

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