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Interpretation Response #05-0246 ([Air Products and Chemicals, Inc.] [Ms. Genette Fields-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: Air Products and Chemicals, Inc.

Individual Name: Ms. Genette Fields-Smith

Location State: PA Country: US

View the Interpretation Document

Response text:

Nov 30, 2005


Ms. Genette Fields-Smith                     Reference No. 05-0246
Air Products and Chemicals, Inc.
7201 Hamilton Blvd.
Allentown, PA 18195-1501

Dear Ms. Fields-Smith:

This is in response to your letter requesting clarification of the definition for “offeror” under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as it applies to certain operations performed by Air Products and Chemicals Inc. (APCI). You state that APCI drivers unload tankers of hazardous materials into pumper trucks at various locations for customers. The customers then transport the loaded pumper trucks to one of their job sites. You ask whether APCI is an offeror (shipper) in such scenarios.

Transportation ends once the consignee takes physical delivery of the hazardous materials; therefore, APCI’s offeror responsibilities stop when the hazardous materials are delivered to the customer, regardless of the location of the delivery.

I hope this information is helpful. Please contact this office should you have additional questions.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.2 General requirements