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Interpretation Response #08-0160 ([Mr. John H. Hawn])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. John H. Hawn

Location State: IA Country: US

View the Interpretation Document

Response text:

June 25, 2008

Mr. John H. Hawn

P.O. Box 124

Dunlap, IA 51529-0124

Ref. No. 08-0160

Dear Mr. Hawn:

This responds to your May 12, 2008 letter requesting clarification on the registration requirements in 49 CFR Part 107, Subpart G. Specifically, you ask if you must register and pay a registration fee.

According to your letter, you are a gas distributor for Sinclair. Your dealers order fuel, which is delivered to them by Sinclair in Sinclair"s trucks. The gas delivery is billed to you and you collect payment from the dealers. You do not own gas stations nor do you operate the motor vehicles that deliver gas.

In accordance with 49 CFR 107.601, shippers and carriers of certain quantities of hazardous materials must register with the Pipeline and Hazardous Materials Safety Administration and pay a registration fee. Because you are neither a shipper nor a carrier, based on the information provided in your letter, it is the opinion of this Office that you are not subject to the registration requirements.

I hope this answers your inquiry.


Susan Gorsky

Regulations Officer

Office of Hazardous Materials Standards

107.601 171.1

Regulation Sections

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