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Interpretation Response #01-0258 ([Carver Boat Corporation, LLC] [Mr. Jeff Guenther])

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

Interpretation Response Details

Response Publish Date:

Company Name: Carver Boat Corporation, LLC

Individual Name: Mr. Jeff Guenther

Location State: WI Country: US

View the Interpretation Document

Response text:

November 16, 2001


Mr. Jeff Guenther                              Reference No.: 01-0258
Carver Boat Corporation, LLC
P. 0. Box 1010
Pulaski, WI 54162-1010

Dear Mr. Guenther:

This is in response to your letter concerning the applicability of the registration requirements to small quantity hazardous waste generators.  Your letter states that Carver Boat Corporation has two separate facilities, each of which offers one to two drums of hazardous waste at a time on separate manifests.  You are of the opinion that Carver Boat Corporation is not required to register, if it does not offer for transportation quantities of hazardous waste in non-bulk packagings that require placarding.  You also asked whether the placarding requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) apply to individual shipments from each facility or to the combined total from the two facilities.

You are correct that Carver Boat Corporation is not required to register if it does not offer for transportation or transport in commerce a quantity of hazardous material that requires placarding under the provisions of subpart F of part 172 of the HMR and does not engage in any other activity specified in 49 CFR 107.601. To determine placarding requirements, each shipment should be considered separately.  Paragraph (c) of § 172.504 of the HMR provides a placarding exception for a transport vehicle or freight container containing less than 454 kg (1,001 lbs) aggregate gross weight of hazardous materials covered by Table 2 of § 172.504(e). The exception does not apply to Table 2 materials contained in bulk packagings.

I trust this satisfies your inquiry.




John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
107.601 Applicability