Paul Melander - Comment

I have reviewed this NPRM and have the following thoughts/questions for your consideration. 1. NFPA 498, Section 4.1.4.1 – warning sign. Is it a good practice to advertise to the public (and thieves) that explosives are here? 2. NFPA 498, Section 4.2.1.1 and .2 – Will the inspection for hot tires, hot wheel bearing, hot brakes require infra-red devices? Who will establish the inspection methods? 3. NFPA 498, Section 4.2.8 reads “No vehicle transporting other hazardous materials shall be parked in a safe haven unless the materials being transported are compatible with explosives.” How does one determine compatibility? Does one use 177.848? The proposed rule should clarify this. 4. NFPA 498, Section 4.3.3 does not prohibit persons other than Law enforcement and security personnel from carrying firearms. It says “Law enforcement and security personnel shall be permitted to carry firearms where specifically authorized by the authority having jurisdiction.” Is the authority the Local, State or Federal government? How does one know who is the “authority having jurisdiction”? In times past, many DOD shipments required armed drivers. 5. The NFPA has a 2010 edition of NFPA 498. Should the rule adopt the 2010 in lieu of the 2006? 6. Should FMCSA amend 397.5 to refer to 177.835 (k) as a cross reference? 7. Will FMCSA amend its regulatory guidance for 397.5 once PHMSA completes its final rule?