This article examines PHMSA’s recent proposal to revise the HMR to allow DOT-approved fireworks certification agencies; see PHMSA 2010-0320 (HM-257), Fed. Reg. Vol. 77, No 169, 52636 et seq.. PHMSA is seeking comments regarding whether a two-track approach to securing approvals of explosives is both warranted and practical. One track is the current PHMSA approvals…
