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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 #07-0054 ([FedEx Express] [Mr. Marvin A. Sudduth])

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

Interpretation Response Details

Response Publish Date:

Company Name: FedEx Express

Individual Name: Mr. Marvin A. Sudduth

Location State: TN Country: US

View the Interpretation Document

Response text:

Apr 3, 2007


Mr. Marvin A. Sudduth                Reference No. 07-0054
FedEx Express
Corporate Safety
3670 Hacks Cross Road
Building G, 2nd Floor
Memphis, TN 38125-8800

Dear Mr. Sudduth:

This is in response to your February 27, 2007 letter regarding training requirements for offerors of hazardous materials shipped under the small quantity exception in § 173.4 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180). Specifically you ask if the training requirements in Part 172, Subpart H apply when offering hazardous materials for transportation under § 173.4.

The answer is no. Materials that meet the requirements of § 173.4 are not subject to any other requirements of the HMR. Therefore, persons who ship hazardous materials under the provisions of § 173.4 are not subject to the training requirements of Part 172, Subpart H. Although training and recordkeeping are not required under Part 172, Subpart H, a person who offers small quantity shipments is responsible for properly classifying the material, determining that the material may be shipped as a small quantity and otherwise ensuring compliance with the provisions of § 173.4. Thus, persons who ship hazardous materials under the small quantity exception will find it necessary to acquire the basic knowledge necessary to understand the provisions in § 173.4 and the provisions applicable to classifying the hazardous material they intend to ship under the small quantity exception.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



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

172. Subpart H

Regulation Sections

Section Subject
172.102 Special provisions
173.4 Small quantities for highway and rail