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Question 1: How does the HMSP Program Improvement policy affect current HMSP holders who are submitting renewal applications?
Guidance: Once an HMSP becomes non-temporary, section 385.407 no longer applies to the carrier’s ability to renew its HMSP. Therefore, as long as an HMSP holder submits its biennial update (MCS-150B) and is not in violation of any of the conditions for suspension or revocation in section 385.421, the HMSP remains valid.
Question 2: How are the recommendations from FMCSA’s study of the HMSP program being implemented?
Guidance: FMCSA has separated the initial application requirements from those for maintenance and renewal of a HMSP. Therefore, the conditions set forth in section 385.407 apply only to initial applicants and Temporary HMSP holders.
Once the HMSP goes into a non-temporary status, it is then subject to the conditions for suspension and revocations in section 385.421. Specifically, for implementation of the recommendations mentioned in Question 3, section 385.421(a)(5) is used as the basis for determining whether a carrier is identified for enhanced oversight.
Basically, FMCSA has added 3 conditions to SMS in order to identify carriers for “enhanced oversight.” These conditions are:
a. The Hazardous Materials (HM) Compliance BASIC is above threshold for 2 consecutive months;
b. Two BASICs, other than the HM Compliance BASIC, are above threshold for 2 consecutive months; or
c. There is insufficient data (no BASIC scores) for 48 consecutive months and the safety rating is ≥ 4 years old.
Question 3: How do I apply for a Hazardous Materials Safety Permit?
Guidance: A carrier would file the MCS-150B form to start the application process. A carrier that does not have a USDOT Number will receive one by filing the MCS-150B.
Downloadable versions of the MCS-150B are available on our web site at: www.fmcsa.dot.gov.
You can also apply online at our website: www.fmcsa.dot.gov.
Question 4: Where can I obtain the MCS-150B form?
Guidance: Hard copies of the MCS-150B are available through each FMCSA Division Office. Information about the location of Division Offices is available on FMCSA’s website at: www.fmcsa.dot.gov.
Downloadable versions of the MCS-150B are available on FMCSA’s web site. You can also register online on FMCSA’s website.