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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 #23-0015

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

Interpretation Response Details

Response Publish Date:

Company Name: UralKali Trading

Individual Name: Marcel Cisneros

Location State: FL Country: US

View the Interpretation Document

Response text:

July 17, 2023

Marcel Cisneros
UralKali Trading
3031 N Rocky Point Dr.
Suite 115
Tampa, FL  33607

Reference No. 23-0015

Dear Mr. Cisneros:

This letter is in response to your March 1, 2023, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of ammonium nitrate-based fertilizer. Specifically, you request classification of your material, known by the trade name of "NS 30:7."

Under § 173.22, it is the shipper's responsibility to properly classify a hazardous material in accordance with classification criteria provided in the HMR prior to offering it for transportation to—or within—the United States. This Office does not normally perform this function. In accordance with Special Provision 150 of § 172.102, ammonium nitrate-based fertilizer must be classified using the procedures of the UN Manual of Tests and Criteria, Part III, Section 39, "Classification Procedure and Criteria Relating to Solid Ammonium Nitrate Based Fertilizers" (incorporated by reference, see § 171.7). If your material meets the composition and testing requirements described in Section 39 for classification as UN 2067, a competent authority approval is not needed for transportation. If your material does not fulfill the requirements for UN 2067, you may need to obtain a competent authority approval prior to offering it for transportation, in accordance with § 107.709.

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

107.709, 171.7, 172.102, 173.22

Regulation Sections

Section Subject
107.709 Processing of an application for approval, including an application for renewal or modification
171.7 Reference material
172.102 Special provisions
173.22 Shipper's responsibility