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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #03-0064 ([Henderson and Walton Women"s Center, P.C.] [Ms. Jane Smith])

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

Interpretation Response Details

Response Publish Date:

Company Name: Henderson and Walton Women"s Center, P.C.

Individual Name: Ms. Jane Smith

Location State: AL Country: US

View the Interpretation Document

Response text:

Apr 22, 2003


Ms. Jane Smith                Reference No. 03-0064
Henderson and Walton Women’s Center, P.C.
806 St. Vincent’s Drive, Suite 500
Birmingham, AL 35205

Dear Ms. Smith:

This is in response to your letter dated February 25, 2003, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you requested information on who is considered a offeror of hazardous material and thus subject to the DOT hazmat training requirements in Part 172, Subpart H.

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 paper to verify compliance with the HMR or international equivalents, signing-hazardous material certifications on shipping papers, placing hazardous materials markings or placards on vehicles or packages, and providing placards to a carrier.  Therefore, a company that performs offeror functions, such as the closing of packages, is a hazmat employer and is subject to § 172.704.

I hope this satisfies your request.



John A Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.704 Training requirements