# Office of Motor Carrier Safety — Hazardous Materials Safety Interpretation

- **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:** Not available
- **summary:** 00-0053 response to Office of Motor Carrier Safety concerning 173.22.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000053.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
400 Seventh Street, S.W.
Washington, D.C.
20590
Special Programs
Research and
Administration
• MAR .. / 2000
Mr. Robert J. Brown, Jr.
Hazardous Materials Specialist
Ref. No: 00-0053
Office of Motor Carrier Safety
201 Mission Street, Suite 2100
San Francisco, CA 94105
Dear Mr. Brown:
This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR;
49 CFR Parts 171-180). Specifically you ask whether a shipment intended for international
transportation qualifies for domestic exceptions from the HMR. In addition, you asked whether a
shipment being prepared for transportation by highway in Mexico for delivery to the US may take
advantage of the exceptions in the HMR prior to entering the US.
A shipment being prepared for transportation by highway in the US for delivery to a foreign destination
placarding. This is true regardless of the destination. However, when preparing a shipment of
may take advantage of any domestic exceptions including domestic proper shipping names and
hazardous materials in a foreign country, it must comply with that country's regulations. A shipment
qualifies for the exceptions from the HMR only after entering the US.
I hope this information is helpful.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
000053
173.22

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U.S. DEPARTMENT OF TRANSPORTATION
OFFICE OF MOTOR CARRIER SAFETY
WESTERN RESOURCE CENTER
Lavalle
201 Mission Street, Suite 2100
San Francisco, CA 94105
$173.22
IN REPLY REFER TO
WRC-HMS
00-0053
Research and Special Programs Administration
400 7th Street, S.W.
Office of Hazardous Materials
: Standards DHM-10
Washington, D.C.
20590
Ref: Clarification letter dated February 25, 1997, sent to Mr.
Keith R. McCann of I and P Trucking, Ltd, copy attached.
placarding of Class 9 material. The clarification letter states
The referenced letter dealt with the domestic exception for
placarding exception granted by 172.504 (f) (9) when being
in part that even international shipments may be eligible for the
transported within the United States.
This office is requesting a further clarification concerning the
for domestic transportation. There is some confusion as to
applicability of the exceptions granted in 49 CFR Parts 100-185
Mexico can be treated as domestic or international shipments.
whether shipments entering or leaving the United States into
activities of our inspectors and our State partners.
The clarification of this issue will assist the border inspection
that we want clarified we pose the following questions:
In order that we may communicate more clearly the requirements
.Q-1 May a shipment being prepared for transportation by highway
in the United States for delivery to Mexico in accordance with 49
including domestic proper shipping names and placarding?
CFR Parts 100-185 take advantage of all domestic exceptions
Plac
Q-2 Would the same hold true for shipments transported by highway
through Mexicoto other countries of Central and South America?
Q-3 May a shipment being prepared
in Mexico for delivery to the United States in accordance with
for transportation by highway
including domestic proper shipping names and placarding prior to
49 CFR Parts 100-185 take advantage of all domestic exceptions
entering U.S. territory?
entered the United States? Once these shipments have entered the
exceptions.
U.S. Customs compound are they now eligible for all the domestic

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the Maquiladoras?
Q-4 would the same answer for 2-3 hold true for shipments made by
highway from other countries of Central and South America?
0-5 Would the same answer to l-3 hold true for shipments by
Sincerely yours,
Robert J. Brown, Jr.
Hazardous Materials Specialist
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