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Interpretation Response #06-0113 ([RBC Dam Rauscher] [Mr.. Jay Jensen ])

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

Interpretation Response Details

Response Publish Date:

Company Name: RBC Dam Rauscher

Individual Name: Mr.. Jay Jensen 

Location State: UT Country: US

View the Interpretation Document

Response text:

Jul 27, 2006


Mr.. Jay Jensen                 Reference No. 06-0113
RBC Dam Rauscher
299 South Main
Suite 2000
Salt Lake City, UT 84111

Dear Mr. Jensen:

This is in response to your May 12, 2006 letter and subsequent telephone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -180). Specifically, you ask if the HMR apply to the transportation of jet fuel by motor vehicle within the boundaries of a privately owned industrial park. You provide the following scenario:

The fuel truck and the jet fuel are owned by Gas Busters Social Club, LLC. Gas Busters Social Club, LLC consists of individual members who use the fuel truck to fuel private aircraft for recreational purposes. The aircraft are located in hangars in the industrial park. The fuel truck is operated on private roads, strictly within the boundaries of the industrial park.

The movement of hazardous material that occurs on private roads entirely within a contiguous facility boundary where public access is restricted is not commercial transportation and therefore is not subject to the requirements of the HMR. The HMR do not apply to motor vehicle movements of a hazardous material exclusively within a contiguous facility boundary where public access is restricted, except to the extent that the movement is on or crosses a public road. If it is, access to the public road must be restricted by signals, lights, gates, or similar controls.

I hope this information is helpful. Please contact us if you require additional assistance.



John Gale
Chief, Standards Development
Office of Hazardous Materials Standards

171.1 (d)

Regulation Sections

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