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Interpretation Response #00-0231 ([Mansour, Gavin, Gerlock & Manos Co., L.P.A.] [Mr. Samuel R. Martillotta])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Mansour, Gavin, Gerlock & Manos Co., L.P.A.

Individual Name: Mr. Samuel R. Martillotta

Location State: OH Country: US

View the Interpretation Document

Response text:

August 18, 2000


Mr. Samuel R. Martillotta                      Ref No. 00-0231
Mansour, Gavin, Gerlock & Manos Co., L.P.A.
55 Public Square
Cleveland, Ohio 44113

Dear Mr. Martillotta:

This responds to your recent letter concerning the Hazardous Materials Registration Program.  Specifically, you ask whether separately incorporated, wholly owned subsidiaries of a company are required to register as separate entities.

The answer is yes.  The registration and fee requirements established in 49 CFR Part 107, Subpart G, apply to any person who offers for transportation or transports hazardous materials subject to the applicability criteria in § 107.601. The definition of  “person”  includes a firm, co-partnership, corporation, company, association, or joint-stock association (see 49 CFR 171.8). Separately incorporated subsidiaries of a parent company must register individually.  Thus, for the scenario described in your letter, Companies A, B, C, D, and E must each file a registration statement and pay the appropriate registration fee.  Each company should use the Small Business Administration size criteria in 13 CFR 121.201 applicable to its own revenues or number of employees and not the aggregate figure for all affiliates to determine if it may register as a small business.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.



Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
107.601 Applicability