Interpretation Response #98-0260 ([Bayer Corporation] [Mr. Robert C. Blake])

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

Interpretation Response Details

Response Publish Date: 10/27/1998

Company Name: Bayer Corporation

Individual Name: Mr. Robert C. Blake

Location State: PA Country: US

View the Interpretation Document

Response text:

OCT 27, 1998

Mr. Robert C. Blake                          Ref. No. 98-0260

Materials Management Distribution Safety

and Regulatory Affairs

Bayer Corporation

100 Bayer Road

Pittsburgh, PA 15205-9741

Dear Mr. Blake:

This is in response to your letter dated August 28, 1998, requesting clarification of responsibility for loading and unloading packages of hazardous materials under the Hazardous Materials Regulations (HMR; 49 CFRParts 171-180).

It is the carrier's responsibility to comply with loading and unloading requirements. However, it is possible for shippers to conduct functions of a carrier, such as loading a vehicle trailer. In the event a shipper conducts or participates in the loading process of a hazardous material onto a transport vehicle, they must comply, as does the carrier, with applicable requirements of the HMR (§ 173.30).

I hope this satisfies your inquiry. If this office can be of further assistance, please contact us.

Sincerely,

Dalmer F. Billings

Chief, Standards Development

Office of Hazardous Materials Standards

173.30

Regulation Sections