Green Trucking, LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 October 24, 2024 Ms. Diana Trejo General Manager Green Trucking LLC 15530 Texaco Ave. Paramount, CA 90723 Reference No. 24-0065 This letter is in response to your July 11, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to transporting Class 9 materials and placarding. In your email, you ask whether a placard is needed on a vehicle transporting Class 9 materials and whether Commercial Driver’s License (CDL) drivers transporting Class 9 materials need a hazardous material (hazmat) endorsement. We have paraphrased and answered your questions as follows: Q1. You ask whether a shipment containing “UN3166, Vehicle, flammable liquid powered or Vehicle, fuel cell, flammable liquid powered, 9” and/or “UN3171, Battery-powered vehicle or Battery-powered equipment, 9” needs to be labeled or placarded. A1. The answer is that neither labels nor placards are required. Provided your shipments are made under the provisions of § 173.220, materials offered as “UN3166, Vehicle, flammable liquid powered or Vehicle, fuel cell, flammable liquid powered, 9” and/or “UN3171, Battery-powered vehicle or Battery-powered equipment, 9” are not subject to the requirements of marking, labeling, and placarding when transported by vehicle or rail car—see § 173.220(h)(1). However, permissive placarding is authorized—see § 172.502(c). Q2. You ask whether the drivers in the scenario listed in question Q1 are required to have a hazmat endorsement on their CDLs when there are no placards displayed on the vehicle. A2. The answer is no. For purposes of 49 CFR Part 383 and the applicability of the CDL hazmat endorsement, a “hazardous material” is defined in 49 CFR 383.5 as a material that has been designated as hazardous under 49 U.S.C. 5103 and is required to be placarded under Subpart F of 49 CFR Part 172; or any quantity of a material listed as a select agent or toxin in 42 CFR Part 73. For Class 9 materials, a Class 9 placard is not required for domestic transportation, including that portion of international transportation—defined in § 171.8—which occurs within the United States.#

Page 2Q3. You ask whether the permissive display of Class 9 placards on a container or vehicle transporting “UN3166, Vehicle, flammable liquid powered or Vehicle, fuel cell, flammable liquid powered, 9” and/or “UN3171, Battery-powered vehicle or Battery- powered equipment, 9” triggers the requirement for a driver to have a hazmat endorsement on their CDL. A3. The answer is no. Permissive placarding does not trigger the requirement for a hazmat endorsement on a CDL, see A2 above. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Alexander Wolcott Acting Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 31200 New Jersey Ave, SE Washington, DC 20590 Dear Pipeline and Hazardous Materials Safety Administration, I would like to respectfully request an interpretation regarding a shipment of Vehicle, Flammable liquid powered and Battery-powered vehicle/Battery-Powered equipment. I have a project in Los Angeles, CA that would like me to haul this product. The shipper is using a straight Bill of Lading with the attached Multimodal Dangerous Good Form J These shipments contain Class 9 UN3166 & UN3171. My understanding of the hazmat laws and CDL endorsement regulations is: 1. Per 49 CR 172.504 (9) only needs to be labeled, not placarded 2. Our CDL drivers can transport it without a hazmat endorsement, not placarded 3. If the customer chooses to put class 9, UN3166 & UN3171 placards on the container instead of using labels to ID the product inside, does the fact that the container is ID with class 9 placards now make our drivers subject to needing a hazmat endorsement? Or is it correct to say that the Class 9 UN3166 & UN3171 placards are exempt from needing the hazmat endorsement? Would you please let us know if our interpretation of the law is correct? I believe your response letter would cover the product we want to transport. Respectfully, Denalo Diana Trejo General Manger Green Trucking LLC 15530 Texaco Ave. www.greentruckingllc.com Paramount, CA 90723 (562) 630-1936#

Page 4PYEONGTAEK, 96271 SOUTH KOREA respects in proper condition for transport according to the applicable international and national government regulations. 8. This shipment is within the limitations prescribed for: 9. Additional Handling Information PASSENGER AND CARGO CARGO ONLY 10. Vessel and Voyage number 11. Port of Loading MSC LAUREN / 429S LONG BEACH 12. Port of Discharge 13. Destination BUSAN 14. Shipping Marks *Number and kind of packages; description of goods Gross Mass (Kgs) Net Mass Cube (m3) UN3166, VEHICLE, FLAMMABLE LIQUID POWERED, CLASS 9 2021 LEXUS NX VIN#: JTJSJRDZ7M2150097 1,896.04 13.93 2023 TOYOTA SIENNA VIN#: 5TDJSKFC3PS078954 2,097.89 17.64 Total Vehicle Count: 2 Total Cube (m3): 31.58 EMS Code: F-E, S-E Emergency Contact: INFOTRAC +1 352-323-3566 / 1-800-535-5053 Other Details 15. Container No. 16. Seal Number (s) 17. Container Size & Type 18. Tare Mass (Kg) 19. Total Gross (incl. tare) (Kg) TCNU8620852 UL7315626 40HC 3,993.92 CONTAINER / VEHICLE PACKING CERTIFICATE 21. RECEIVING ORGANIZATION RECEIPT I hereby declare that the goods described above have been Received the above number of packages/containers/trailers in placed/loaded into the container/vehicle identified above in apparent good conditions, unless stated hereon: RECEIVING accordance with the applicable provisions. **MUST BE ORGANIZATION RE-MARKS: COMPLETED AND SIGNED FOR ALL CONTAINER/VEHICLE LOADS BY PERSON RESPONSIBLE FOR PACKING/LOADING 20. Name of Company (stamp & signature mandatory) Haulier's Name 22. Name of Company (OF SHIPPER PREPARING THIS NOTE) (stamp & signature are mandatory) CFR Classic CFR Classic Name / Status of Declarant: Vehicle reg no. Name / Status of Declarant: Antonio Camarena Antonio Camarena Place and Date Signature and Date Place and Date LONG BEACH 719/2024 LONG BEACH 7/9/2024 Signature of Declarant Driver's Signature Signature of Declarant dea del *DANGEROUS GOODS You must specify proper shipping name, hazard class, UN No., Packaging group, (where assigned) Marine pollutant and observe the mandatory requirements, under applicable national and international governmental regulations. For the purpose of the IMDG Code see IAL GPC F-064 Rev. (-) 06/18 5.4.1. ** For the purpose of the IMDG Code see 5.4.2#

Page 5PYEONGTAEK, 96271 SOUTH KOREA respects in proper condition for transport according to the applicable international and national government regulations. 8. This shipment is within the limitations prescribed for: 9. Additional Handling Information PASSENGER AND CARGO CARGO ONLY 10. Vessel and Voyage number 11. Port of Loading MSC LAUREN / 429S LONG BEACH 12. Port of Discharge 13. Destination BUSAN 14. Shipping Marks *Number and kind of packages; description of goods Gross Mass (Kgs) Net Mass Cube (m3) UN3166, VEHICLE, FLAMMABLE LIQUID POWERED, CLASS 9 2009 HONDA CIVIC HYBRID VIN#: JHMFA36299S014075 1,305.00 11.21 2023 TOYOTA SEQUOIA VIN#: 7SVAAABA3PX015306 2,805.50 20.73 Total Vehicle Count: 2 Total Cube (m3): 31.94 Emergency Contact: INFOTRAC +1 352-323-3566 / 1-800-535-5053 EMS Code: F-E, S-E Other Details 15. Container No. 16. Seal Number (s) 17. Container Size & Type 18. Tare Mass (Kg) 19. Total Gross (incl. tare) (Kg) MRKU4484566 UL7315627 40HC 4,110.50 CONTAINER / VEHICLE PACKING CERTIFICATE 21. RECEIVING ORGANIZATION RECEIPT I hereby declare that the goods described above have been Received the above number of packages/containers/trailers in placed/loaded into the container/vehicle identified above in apparent good conditions, unless stated hereon: RECEIVING accordance with the applicable provisions. **MUST BE ORGANIZATION RE-MARKS: COMPLETED AND SIGNED FOR ALL CONTAINER/VEHICLE LOADS BY PERSON RESPONSIBLE FOR PACKING/LOADING 20. Name of Company (stamp & signature mandatory) Haulier's Name 22. Name of Company (OF SHIPPER PREPARING THIS NOTE) (stamp & signature are mandatory) CFR Classic CFR Classic Name / Status of Declarant: Vehicle reg no. Name / Status of Declarant: Antonio Camarena Antonio Camarena Place and Date Signature and Date Place and Date LONG BEACH 7/9/2024 LONG BEACH 7/9/2024 Signature of Declarant Driver's Signature Signature of Declarant del del *DANGEROUS GOODS You must specify proper shipping name, hazard class, UN No., Packaging group, (where assigned) Marine pollutant and observe the mandatory requirements, under applicable national and international governmental regulations. For the purpose of the IMDG Code see 5.4.1. ** For the purpose of the IMDG Code see 5.4.2 IAL GPC F-064 Rev. (-) 06/18#

Page 6PYEONGTAEK, 96271 SOUTH KOREA respects in proper condition for transport according to the applicable international and national government regulations. 8. This shipment is within the limitations prescribed for: 9. Additional Handling Information PASSENGER AND CARGO CARGO ONLY 10. Vessel and Voyage number 11. Port of Loading MSC LAUREN / 429S LONG BEACH 12. Port of Discharge 13. Destination BUSAN ( 14. Shipping Marks *Number and kind of packages; description of goods Gross Mass (Kgs) Net Mass Cube (m3) UN3166, VEHICLE, FLAMMABLE LIQUID POWERED, CLASS 9 2022 TOYOTA SIENNA VIN#: 5TDKRKEC5NS084530 2,091.08 17.64 2023 TOYOTA HIGHLANDER VIN#: 5TDABRCH9PS600172 2.038.92 16.43 Total Vehicle Count: 2 Total Cube (m3): 34.07 EMS Code: F-E, S-E Emergency Contact: INFOTRAC +1 352-323-3566 / 1-800-535-5053 Other Details 15. Container No. 16. Seal Number (s) 17. Container Size & Type 18. Tare Mass (Kg) 19. Total Gross (incl. tare) (Kg) MSKU1315610 UL7315629 40HC 4,130.00 CONTAINER / VEHICLE PACKING CERTIFICATE 21. RECEIVING ORGANIZATION RECEIPT I hereby declare that the goods described above have been Received the above number of packages/containers/trailers in placed/loaded into the container/vehicle identified above in apparent good conditions, unless stated hereon: RECEIVING accordance with the applicable provisions. **MUST BE ORGANIZATION RE-MARKS: COMPLETED AND SIGNED FOR ALL CONTAINER/VEHICLE LOADS BY PERSON RESPONSIBLE FOR PACKING/LOADING 20. Name of Company (stamp & signature mandatory) Haulier's Name 22. Name of Company (OF SHIPPER PREPARING THIS NOTE) (stamp & signature are mandatory) CFR Classic CFR Classic Name / Status of Declarant: Vehicle reg no. Name / Status of Declarant: Antonio Camarena Antonio Camarena Place and Date Signature and Date Place and Date LONG BEACH 7/9/2024 LONG BEACH 7/9/2024 Signature of Declarant Driver's Signature Signature of Declarant del del *DANGEROUS GOODS You must specify proper shipping name, hazard class, UN No., Packaging group, (where assigned) Marine pollutant and observe the mandatory requirements, under applicable national and international governmental regulations. For the purpose of the IMDG Code see IAL GPC F-064 Rev. (-) 06/18 5.4.1. ** For the purpose of the IMDG Code see 5.4.2#

Page 78 This shipment is within the limitations prescribed for: 9 Additional handling information PASSENGER AND CARGO CARGO ONLY 10 Vessel and Voyage number 11 Port of loading MS LAUREN V429S LONG BEACH (PORT) 12 Port of discharge 13 Destination BUSAN (PORT) 14 Shipping Marks *Number and kinds of packages; description of goods Gross mass (kg) Net mass (kg) Cube (m3) UN3171, BATTERY-POWERED VEHICLE OR BATTERY-POWERED EQUIPMENT, CLASS 9 2023 TESLA MODEL 3 VIN# 5YJ3E1EAXPF603846 - EMS Code: F-A,S-l 1,751.80 KGS 1,751.80 KGS 12.52 CBM 2022 TESLA MODEL 3 VIN# 5YJ3E1EC7NF265305 - EMS Code: F-A,S-l 1,927.80 KGS 1,927.80 KGS 12.43 CBM Total Vehicle Count: Total Cube (m3): 24.95 CBM INFOTRAC Emergency Contact: +1 352-323-3500 / 1-800-535-5053 Other Details 15 Container identification no. 16 Seal numbers) 1 Container size & 18 Tare mass (kg) type 19 Total gross (incl. tare) (kg) kg MRKU2020416 UL7315630 40 HC 3679.60KGS CONTAINER / VEHICLE PACKING CERTIFICATE 21 RECEIVING ORGANIZATION RECEIPT I hereby declare that the goods described above have been placed/loaded into the container/vehicle identified above in and conditions, unless stated hereon: RECEIVING ORGANIZATION RE-MARKS: Received the above number of packages/containers/trailers in apparent good order accordance with the applicable provisions. **MUST BE COMPLETED AND SIGNED FOR ALL CONTAINER/EHICLE LOADS BY PERSON RESPONSIBLE FOR PACKING/LOADING 20 Name of company (stamp & signature are mandatory) Haulier's name 22 Name of company (OF SHIPPER PREPARING THIS NOTE) (stamp & signature are mandatory) INTERNATIONAL AUTO LOGISTICS INTERNATIONAL AUTO LOGISTICS Name/Status of declarant: onio Camareven Vehicle reg no. Name/Status of declarant: aurera Place and date: LONG BEACH (PORT) 7/9/2024 Signature and date Place and date: LONG BEACH (PORT) 7/9/2024 Signature of declarant SIGNATURE DRIVER'S Signature of declarant *DANGEROUS GOODS You must specify proper shipping name, hazard class, UN No., Packaging group, (where assigned) Marine pollutant and observe the mandatory requirements, under applicable national and international governmental regulations. For the purpose of the IMDG Code see 5.4.1. IAL GPC F-064 Rev. (-) 06/18 •* For the purpose of the IMDG Code see 5.4.2#