USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

Interpretation Response #03-0102 ([Palava Consulting Services] [Mr. Richard Palava])

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

Interpretation Response Details

Response Publish Date:

Company Name: Palava Consulting Services

Individual Name: Mr. Richard Palava

Location State: FL Country: US

View the Interpretation Document

Response text:

Oct 23, 2003


Mr. Richard Palava

Palava Consulting Services

1735 Indian Wells Avenue

Ocala, Florida 34472-8402

Reference No. 03-0102

Dear Mr. Palava:

This is in further response to your April 2, 2003 letter requesting clarification of the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to carriers transporting hazardous materials in commerce. You were specifically concerned about the applicability of the HMR to transport vehicles that have been cleaned and purged of the hazardous materials they previously contained.

Our May 27, 2003 reply to your letter indicated that the HMR do not apply to the transportation of an empty trailer that has been cleaned and purged of hazardous materials. We should have noted that, for cargo tank motor vehicles and other bulk packagings that are marked to indicate conformance with the packaging specification requirements in the HMR, the packaging must conform to all applicable regulatory requirements even if the packaging has been cleaned and purged of all hazardous materials. Thus, a specification cargo tank motor vehicle that has been cleaned and purged must comply with all applicable specification, requalification, and maintenance requirements or the specification marking must be covered or removed.

I hope this information is helpful. Please accept my apology for any confusion our previous letter may have caused.


Susan Gorsky

Senior Regulations Specialist

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions