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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 #19-0031

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

Interpretation Response Details

Response Publish Date:

Company Name: TDA, Inc

Individual Name: Tom Dunaway

Location State: AL Country: US

View the Interpretation Document

Response text:

June 11, 2019

Tom Dunaway
TDA, Inc.
502 Big Creek Drive
Delta, AL  36258

Reference No. 19-0031

Dear Mr. Dunaway:

This letter is in response to your March 11, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to registration.  Specifically, you ask if a person is required to submit a hazardous materials registration and payment if they offer for transportation or transport less than 55 pounds of a Division 1.1, 1.2, or 1.3 (explosive) material.

The answer is yes, unless it is an activity of a farmer, as defined in § 171.8, that is in direct support of farming operations (see § 107.601(b)).  In accordance with § 107.601(a)(6), the registration and fee requirements apply to any person who offers for transportation, or transports, in foreign, interstate or intrastate commerce a quantity of hazardous material that requires placarding, under provisions of subpart F of part 172.  Subpart F of part 172 requires that any quantity of a Division 1.1, 1.2, or 1.3 (explosive) material be placarded; the registration fee applies to both a person who offers for transportation or transports any quantity of a Division 1.1, 1.2, or 1.3 (explosive) material.  Being below the threshold quantity in § 107.601(a)(2) does not exclude a person from possibly being subject to the condition of § 107.601(a)(6).

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


Dirk Der Kinderen
Chief, Standards Development
Standards and Rulemaking Division

107.601(a)(2), 107.601(a)(6), 107.601(b), 171.8, 172,

Regulation Sections

Section Subject
107.601 Applicability
171.8 Definitions and abbreviations