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Interpretation Response #07-0121 ([Con Edison Development] [Dr. Raymond Martin    ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Con Edison Development

Individual Name: Dr. Raymond Martin    

Location State: MD Country: US

View the Interpretation Document

Response text:

Oct 16, 2007

Dr. Raymond Martin                                      Reference No. 07-0121

Regional EHS Manager

Con Edison Development

1423 Rock Springs Road

Rising Sun, MD 21009

Dear Dr. Martin:

This is in response to your letter dated May 18, 2007 concerning the applicability of the Hazardous Materials Registration Program as specified in 49 CFR Part 107, Subpart G. According to your letter, your company uses hydrogen gas for cooling at your facility. A carrier delivers hydrogen in 250 ft trailers and removes the empty trailers.

Provided you do not offer or transport the hydrogen described in your letter, you are not required to register. "Person who offers or offeror" is defined in § 171.8 as a person who performs, or is responsible for performing, any pre-transportation function required under this subchapter for transportation of the hazardous material in commerce or who tenders or makes the hazardous material available to a carrier for transportation in commerce. In addition, "carrier" is defined in § 171.8 to mean a person who transports passengers or property in commerce by rail car, aircraft, motor vehicle, or vessel.

I hope this information is helpful.


John A. Gale

Chef, Standards Development

Office of Hazardous Materials Standards

171.8, 107.601

Regulation Sections

Section Subject
107.601 Applicability
171.8 Definitions and abbreviations