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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 #11-0171 ([Reynolds Transport] [Mr. Aaron Carr])

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

Interpretation Response Details

Response Publish Date:

Company Name: Reynolds Transport

Individual Name: Mr. Aaron Carr

Location State: IN Country: US

View the Interpretation Document

Response text:

September 14, 2011




Mr. Aaron Carr

Fleet Manager

Reynolds Transport

Orleans, IN 47452

Reference No. 11-0171

Dear Mr. Carr:

This responds to your July 15, 2011 request for clarification of the requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to the transport of a material you classify as a Class 9 (miscellaneous) hazard material based on the material meeting the definition of a hazardous substance (§ 171.8). You seek confirmation that your drivers are not required to have a hazardous materials endorsement to their commercial driver"s licenses (CDLs) in order to transport this material.

Your understanding is correct that the transportation of your material is subject to shipping paper and labeling requirements. Regarding placarding, in accordance with § 172.504(f)(9), placarding is not required for transportation of Class 9 material when shipped domestically, however, a bulk packaging must be marked with the appropriate identification number on a Class 9 placard, an orange panel, or a white square-on-point display configuration. You may display the identification number on a Class 9 placard even though a placard is not required. Display of the identification number on a placard does not, however, make your drivers subject to the endorsement requirement under 49 CFR 383.93 of the Federal Motor Carrier Safety Regulations (FMCSR). In accordance with the FMCSR, a driver of a commercial motor vehicle transporting hazardous material subject to placarding under the HMR must obtain a hazardous materials endorsement to his or her CDL. Thus, because a placard is not required for domestic transportation of a Class 9 material under the HMR, a hazardous materials endorsement to the CDL is not required.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division

171.8, 172.504

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.504 General placarding requirements