Interpretation Response #01-0292
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
January 11, 2002
Mr. Steve McKenna Reference No. 01-0292
World Logistic Group, Inc.
900 Saddle Ridge Court
Roswell, GA 30076
Dear Mr. McKenna:
This is in response to your letter dated November 15, 2001, concerning the applicability of the Hazardous Materials Registration Program as specified in 49 CFR Part 107, Subpart G. Specifically, you ask if a transportation broker must register.
A broker does not need to register under U.S. DOT's Hazardous Materials Registration Program provided he does not perform a function of an offeror or carrier. Functions of an offeror include, but are not limited to the following: selection of the packaging for a hazardous material, physical transfer of hazardous materials to a carrier, classifying hazardous materials, preparing shipping papers, reviewing shipping papers to verify compliance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) or international equivalents, signing hazardous materials certifications on shipping papers, placing hazardous materials markings or placards on vehicles or packages, and providing placards to a carrier. In addition, carrier is defined in § 171.8 to mean a person engaged in the transportation of passengers or property by: land or water, as a common, contract or private carrier; or civil aircraft.
I hope this satisfies your request.
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards