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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 #22-0122

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: David Fletcher

Location State: TN Country: US

View the Interpretation Document

Response text:

February 2, 2023

David Fletcher
317 Ironwood Circle
Gallatin, TN  37066

Reference No. 22-0122

Dear Mr. Fletcher:

This letter is in response to your July 31, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the Hazardous Materials Registration Program as specified in 49 CFR Part 107, Subpart G. In your letter, you state that your company is a "licensed property broker" that facilitates transportation between shippers and motor carriers and relays basic shipping information to carriers—but never takes physical possession of shipments. Specifically, you ask whether a "licensed property broker" is subject to the HMR and the hazardous materials registration requirements in 49 CFR Part 107, Subpart G.

A licensed property broker does not need to register, provided no function of an offeror or carrier is performed. Functions of an offeror include—but are not limited to—the following: (1) selection of the packaging for a hazardous material; (2) physical transfer of a hazardous materials to a carrier; (3) classifying the hazardous materials; (4) preparing a shipping paper; (5) reviewing shipping papers to verify compliance with the HMR or international equivalents; (6) signing hazardous materials certifications on shipping papers; (7) placing hazardous materials markings or placards on vehicles or packages; and (8) providing placards to a carrier. In addition, a carrier is defined in § 171.8 to mean a person who transports passengers or property in commerce by rail car, aircraft, motor vehicle, or vessel.

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


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

107, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations