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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 #16-0043 ([Cliff Bartley Consulting] [Mr. Cliff Bartley])

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

Interpretation Response Details

Response Publish Date:

Company Name: Cliff Bartley Consulting

Individual Name: Mr. Cliff Bartley

Location State: FL Country: US

View the Interpretation Document

Response text:

Mr. Cliff Bartley
Cliff Bartley Consulting
1421 Lamanto Avenue East
Jacksonville, FL  32211

Reference No. 16-0043

Dear Mr. Bartley:

This letter is in response to your February 22, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to exceptions for vehicles transported by vessel.  Specifically, you seek clarification of your understanding that vehicles shipped in accordance with § 176.905(i)(3) are excepted from the remainder of the HMR and are not required to comply with § 176.905(a)(2).

Your understanding is correct.  The HMR provide modal exceptions under § 173.220(b)(4)(ii) for vehicles transported by vessel that conform to the requirements of § 176.905.  Shipments of vehicles transported in accordance with § 176.905(i)(3) are only subject to United States Coast Guard regulations and are excepted from the HMR.

I hope this information is helpful.  Please contact us if we can be of further assistance.   


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

Regulation Sections

Section Subject
171.2 General requirements
172.204 Shipper's certification
173.35 Hazardous materials in IBCs