Guidanceguidance
98-0242
Chautauqua Metal Finishing Supply — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1of Transportation US. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Special Programs Research and Administration SEP 1 6 1998 Ms. Patricia A. West Ref. No. 98-0242 Chautauqua Metal Finishing Supply P.О. Box 100 Ashville, NY 14710 Dear Ms. West: regarding responsibility for compliance with motor vehicle This is in response to your letter dated August 11, 1998, loading and unloading requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). It is the carrier's responsibility to comply with all applicable loading and unloading requirements (§ 177:800(b)). Any person, including a shipper, who loads or unloads hazardous materials on comply with the applicable loading and unloading requirements a transport vehicle is performing a carrier function and must (S 173.30). I hope this satisfies your request. Sincerely, Transportation Regulations Specialist / office of Hazardous Materials Standards Aplof/ 8513 177.800#
Page 298-0241 CIMFJ Chautauque Metal Fishing Supply A DIVISION OF CHAUTAUQUA CHEMICALS CO., INC. 800-222-4343 NY/WESTERN PA P.O. BOX 100 Mailing Address: 4743 CRAMER DRIVE Shipping Address: 716-763-4114 ASHVILLE ASHVILLE, NY 14710 ASHVILLE, NY 14710 814-455-2795 ERIE 716-328-4860 ROCHESTER 716-763-3555 FAX August 11, 1998 BAlt §17.834 Edward Mazzullo - Director 400 7h Street, SW OHMS Washington, DC 20590 Dear Mr. Mazzullo, We are writing for an interpretation or: the following issue: Where does the liability fall and who's responsibility is it for assuring proper load securement? carrier and are trying to impliment some type of enforcement procedure at our facility. We ship chemicals (hazardous and non-hazardous) and equipment occasionally via common It would be most helpful to us to have your interpretation with any regulatory references to back to know how hard we dare push especially since most wording tends to reference "the carrier". up what we are attempting to do. We feel it is to our best interest to deal with this issue but need Thank you for your prompt response to this matter. Chautauqua Metal Finishing Supply Very truly yours. Hactr Regulatory/Safety Coordinator Patricia A. West Qprob Responsible NACD Distribution Process 8517 Quality • Resp#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.