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Interpretation Response #09-0036 ([Packaging Applications for Dangerous Goods, LLC] [Mr. David C. Gluntz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Packaging Applications for Dangerous Goods, LLC

Individual Name: Mr. David C. Gluntz

Location State: OH Country: US

View the Interpretation Document

Response text:

March 31, 2009







Mr. David C. Gluntz

Packaging Applications for Dangerous Goods, LLC

3583 Blackbottom Court

Columbus, OH 43221-4501


Ref. No. 09-0036


Dear Mr. Gluntz:

This responds to your February 17, 2009 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask a hypothetical question in which you are the president of a manufacturing company that sells UN marked Intermediate Bulk Containers (IBCs) and UN marked drums, thus making you a hazmat employer.  During the course of a sales presentation, you or salespersons that you employ provide company brochures, specification sheets and/or drawings of your products.  You and your employees may also share your thoughts regarding what materials are authorized by the DOT to be transported in your packagings.  Further, you and your employees may share third party compatibility information.  Specifically, you ask if the above described activities of you and your salespersons mean that you and your salespersons are hazmat employees as defined in the HMR. 


The answer is no.  The term "Hazmat employee" is defined in § 171.8 of the HMR.   The term includes persons who design, manufacture, fabricate, inspect, mark, maintain, recondition, repair, or test a package, container, or packaging component that is represented, marked, certified or sold as qualified for use in transporting hazardous material in commerce.  The term does not include functions performed by company salespersons to convey product information (i.e., distribute brochures, specifications, drawings and other information related to UN certified packages) to potential or existing customers. 


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






Charles Betts

Chief, Standards Development

Office of Hazardous Materials Standards



Regulation Sections

Section Subject
171.8 Definitions and abbreviations