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Interpretation Response #22-0064

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

Interpretation Response Details

Response Publish Date:

Company Name: Total Compliance, LLC

Individual Name: Chris Heminger

Location State: OH Country: US

View the Interpretation Document

Response text:

December 22, 2022

Mr. Chris Heminger, CPEA
Senior Partner
Total Compliance, LLC
5859 Morganwood Square
Hillard, OH 43026

Reference No. 22-0064

Dear Mr. Heminger:

This letter is in response to your June 18, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to activities that are not subject to the HMR. Specifically, you state that your client transports hazardous materials by motor vehicle between a facility and a warehouse that it owns, and that the facility and warehouse are on opposite sides of a public road. You further state that whenever hazardous materials are transported between the two buildings, your client marks the public road with yellow hash marks, posts "CAUTION" signs facing each direction of traffic and closes the public road between the facility and warehouse in both directions by placing physical barriers and stop signs. You ask whether your client's controls—as described in your email—can be considered a "contiguous facility boundary" as referenced in § 171.1(d) (Functions not subject to the requirements of the HMR).

The answer is yes. Based on the information you provided in your email, it is the opinion of this Office that your client's operation would be considered a contiguous facility boundary as referenced in § 171.1(d)(4) when access to the public road is restricted by signals, lights, gates, or similar controls.

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


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

171.1(d), 171.1(d)(4)

Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions