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Interpretation Response #09-0266 ([Argonne National Laboratory] [Mr. John Pearson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Argonne National Laboratory

Individual Name: Mr. John Pearson

Location State: IL Country: US

View the Interpretation Document

Response text:

January 8 , 2010




Mr. John Pearson

Materials Science Division

Argonne National Laboratory

9700 South Cass Avenue

Argonne, IL 60439

Ref. No.: 09-0266

Dear Mr. Pearson:

This responds to your letter dated November 9, 2009 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the small quantity exception. Specifically, you ask if the person who classes, ensures compliance, and offers a hazardous material into transportation using the small quantity exception is subject to formal training requirements under the HMR.

The answer is no. Materials that meet the requirements of 49 CFR § 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 formal training requirements of Subpart H in Part 172. A person who offers small quantity shipments under § 173.4 is still responsible for properly classifying and naming the material as well as correctly determining if the material may be shipped as a small quantity. 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 answers your inquiry.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.4 Small quantities for highway and rail