Christenson Transportation, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C 20590 Research and Special Programs Administration JUL 3 2000 Mr. Barry McGowen Ref. No. 00-0110 Christenson Transportation, Inc. P.o. Box 4267 Springfield, MO 65808-4267 Dear Mr. McGowen: This is in response to your letter dated March 22, 2000, and subsequent telephone conversation with a member of my staff concerning the applicability of the hażardous materials registration program under Part 107, Subpart G, of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if your company must register if the only hazardous materials your company transports are marine batteries and propane cylinders. On February 14, 2000, RSPA promulgated, Docket HM-208C (65 FR 7297), which expanded the criteria for persons required to register under Part 107, Subpart G. Effective July 1, 2000, in addition to the existing requirements under § 107.601, any person who offers or transports in commerce a quantity of a hazardous material that requires placarding under Part 172, Subpart F, must register. This additional provision does not apply to those activities of a farmer that are in direct support of one's farming operations. Therefore, provided your company does not transport more than 1,001 pounds (aggregate gross weight) of batteries or propane cylinders, you do not have to register. We hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 17322 000110#

Page 2.... Fax (417) 866-5166 Transportation, inc. P. O. Box 4267 • Springfield, MO 65808-4267 http://ChristensonTrans.com "Serving the USA and Canada" March 22, 2000 248 Reguest 46-00 2:30pC.S.T. 39º Reguest 4-19-00 11:45 A.M 657 Mr. Edward I. Mazzullo Directors Office of Hazardous Materials & Standards US DOT-RSPA (D-HM-10) 400 7TH Street S.W. Washington, DC 20990-0001 Dear Mr. Mazzullo, Reference my telephone conversation with Mr. Johu Gayle of your office this morning, I would like to receive in writing the answers he has given to my questions regarding the following: We have a customer who wishes to load our trucks from their Distribution facility in Springfield, MO to one of their store locations in Nashville, TN with 99% of their volume comprised of non-hazardous commodities, i.e. tents, blankets, camping supplies, fishing rods and reels, wearing apparel, footwear, etc., etc.. On occasion there will be shipments involving commodities such as Coleman gas cylinders (filled) as in the kind and type that screw into a lantern. There will also be Marine batteries, both sealed and fillable. It is our understanding that we do not have to have a Federal Hazmat License to participate in the movement of the above, so long as when handling this material the driver has a current haz mat endorsement on his license, that he has been trained within the last three years on hazardous material handling, and should the volume/weight of any of these hazardous commodities exceed 1,000 Ibs, that the shipper provide the appropriate placards. Please respond to the following and thank you for your assistance! Sincerely, Director of Safety Member American Trucklng Association - Truckload Carrier Conference#