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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 #19-0111

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

Interpretation Response Details

Response Publish Date:

Company Name: Fuelie Systems, Inc.

Individual Name: Thomas Stumpf

Location State: DE Country: US

View the Interpretation Document

Response text:

January 17, 2020

Thomas Stumpf
CEO
Fuelie Systems, Inc.
16192 Coastal Highway
Lewes, DE  19958

Reference No. 19-0111

Dear Mr. Stumpf:

This letter is in response to your August 30, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the domestic transportation of diesel fuel. You reference a Letter of Interpretation (Reference No. 05-0062), stating: "[i]n accordance with § 172.101(b)(3) and (b)(5), you may use either the international or domestic entry in the [Hazardous Material Table (HMT)] for domestic transportation of methanol." With respect to the clarification offered in the letter and noting that it is permissible to use either the international or domestic HMT entry for the domestic transportation of methanol, you ask whether it is similarly permissible to use either the international or domestic entry for the domestic transportation of diesel fuel.

The answer is yes. The HMT includes two entries for diesel fuel, "NA1993" and "UN1202." The "UN1202" entry has an "I" in Column (1) indicating its use for international and domestic transportation (emphasis added). The "NA1993" entry has a "D" in Column (1) indicating its use for domestic transportation only (emphasis added). A person may select either entry for the purposes of domestic transportation.

Please note, the combined or partial use of the domestic and international entry is not permissible. For example, diesel fuel may be described as either "UN1202" or "NA1993" for the purposes of domestic transportation, but a person cannot mark a package containing diesel fuel with "UN1202" while describing it on a shipping paper as "NA1993" or vice versa. Moreover, a person must comply with the applicable requirements assigned to the entry in the HMT.

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

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

172.101(b)(3) (b)(5)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table