{"operation":"document","citation":"00-0053","title":"Office of Motor Carrier Safety — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-03-01","effective_on":null,"summary":"00-0053 response to Office of Motor Carrier Safety concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0053.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0053.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0053","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000053.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh Street, S.W.\nWashington, D.C.\n20590\nSpecial Programs\nResearch and\nAdministration\n• MAR .. / 2000\nMr. Robert J. Brown, Jr.\nHazardous Materials Specialist\nRef. No: 00-0053\nOffice of Motor Carrier Safety\n201 Mission Street, Suite 2100\nSan Francisco, CA 94105\nDear Mr. Brown:\nThis is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR;\n49 CFR Parts 171-180). Specifically you ask whether a shipment intended for international\ntransportation qualifies for domestic exceptions from the HMR. In addition, you asked whether a\nshipment being prepared for transportation by highway in Mexico for delivery to the US may take\nadvantage of the exceptions in the HMR prior to entering the US.\nA shipment being prepared for transportation by highway in the US for delivery to a foreign destination\nplacarding. This is true regardless of the destination. However, when preparing a shipment of\nmay take advantage of any domestic exceptions including domestic proper shipping names and\nhazardous materials in a foreign country, it must comply with that country's regulations. A shipment\nqualifies for the exceptions from the HMR only after entering the US.\nI hope this information is helpful.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n000053\n173.22\n\n<<<PAGE 2>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nOFFICE OF MOTOR CARRIER SAFETY\nWESTERN RESOURCE CENTER\nLavalle\n201 Mission Street, Suite 2100\nSan Francisco, CA 94105\n$173.22\nIN REPLY REFER TO\nWRC-HMS\n00-0053\nResearch and Special Programs Administration\n400 7th Street, S.W.\nOffice of Hazardous Materials\n: Standards DHM-10\nWashington, D.C.\n20590\nRef: Clarification letter dated February 25, 1997, sent to Mr.\nKeith R. McCann of I and P Trucking, Ltd, copy attached.\nplacarding of Class 9 material. The clarification letter states\nThe referenced letter dealt with the domestic exception for\nplacarding exception granted by 172.504 (f) (9) when being\nin part that even international shipments may be eligible for the\ntransported within the United States.\nThis office is requesting a further clarification concerning the\nfor domestic transportation. There is some confusion as to\napplicability of the exceptions granted in 49 CFR Parts 100-185\nMexico can be treated as domestic or international shipments.\nwhether shipments entering or leaving the United States into\nactivities of our inspectors and our State partners.\nThe clarification of this issue will assist the border inspection\nthat we want clarified we pose the following questions:\nIn order that we may communicate more clearly the requirements\n.Q-1 May a shipment being prepared for transportation by highway\nin the United States for delivery to Mexico in accordance with 49\nincluding domestic proper shipping names and placarding?\nCFR Parts 100-185 take advantage of all domestic exceptions\nPlac\nQ-2 Would the same hold true for shipments transported by highway\nthrough Mexicoto other countries of Central and South America?\nQ-3 May a shipment being prepared\nin Mexico for delivery to the United States in accordance with\nfor transportation by highway\nincluding domestic proper shipping names and placarding prior to\n49 CFR Parts 100-185 take advantage of all domestic exceptions\nentering U.S. territory?\nentered the United States? Once these shipments have entered the\nexceptions.\nU.S. Customs compound are they now eligible for all the domestic\n\n<<<PAGE 3>>>\n\nthe Maquiladoras?\nQ-4 would the same answer for 2-3 hold true for shipments made by\nhighway from other countries of Central and South America?\n0-5 Would the same answer to l-3 hold true for shipments by\nSincerely yours,\nRobert J. Brown, Jr.\nHazardous Materials Specialist","truncated":false,"body_characters":3786}