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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 #14-0205 ([RMS Interests, LLC] [Ms. Robin Smith])

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

Interpretation Response Details

Response Publish Date:

Company Name: RMS Interests, LLC

Individual Name: Ms. Robin Smith

Location State: TX Country: US

View the Interpretation Document

Response text:

March 24, 2015

Ms. Robin Smith
Principal Environmental Consultant
RMS Interests, LLC
251 Hidden Creek Drive
Dripping Springs, Texas 78620-4668

Reference No. 14-0205

Dear Ms. Smith:

This is in response to your recent letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to transporting pumps and other mechanical equipment contaminated with the residue of process chemicals, gases, and/or byproducts. You state some of these residues meet the definition of a hazardous material under the HMR. Specifically, you ask if hazardous material residue cannot be removed from the equipment (e.g., without the use of special tools or without possibly rendering the equipment unusable) can this residue be considered integral to the equipment when it is offered for transportation in commerce.

The answer is yes. The HMR do not specifically define what is meant by hazardous material residue that is integral to equipment. It is the opinion of this Office that hazardous material residue in components of equipment or machinery may be considered integral if the residue is necessary to the function of the equipment, its removal would cause damage to the equipment, or it performs some other function necessary to the equipment such that it cannot be removed from the equipment while it is in transportation. Please note that the proper shipping names "Dangerous Goods in Machinery" and "Dangerous Goods in Apparatus" are appropriate shipping names for components of machinery or equipment that contain residual hazardous materials. Materials prepared for transportation using these proper shipping names must comply with the requirements specified in § 173.222.

I hope this satisfies your request.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.222 Dangerous goods in equipment, machinery or apparatus