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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 #98-0572 ([Raloid Corp.] [Mr. Robert A. Robbins, QAR])

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

Interpretation Response Details

Response Publish Date:

Company Name: Raloid Corp.

Individual Name: Mr. Robert A. Robbins, QAR

Location State: MD Country: US

View the Interpretation Document

Response text:

JAN 9, 1998


Mr. Robert A. Robbins, QAR
Defense Contracts Management Command
C/O Raloid Corp.
109 Wabash Ave.
Reisterstown, MD 21136

Dear Mr. Robbins:

This is in response to your letter of December 1, 1997 concerning undeclared shipments of self-propelled vehicles that may be transported by aircraft under the Hazardous Materials Regulations (HMR; 49 CFRParts 171-180).

The broad exceptions provided in § 173.220 for self-propelled vehicles do not negate their designation as a hazardous material. The HMR requires that persons who offer for transportation or transport self-propelled vehicles in commerce must be made aware of the hazards they pose and comply with all appropriate requirements in the HMR to assure their safe transportation.

In a June 14, 1996 notice published in the Federal Register (copy enclosed), this Office provided advisory guidance to persons involved in the "transportation of hazardous materials to ensure that hazardous materials are properly identified, packaged, authorized for transportation, handled, loaded and transported in conformance with the HMR. The purpose of this notice is to alert shippers and carriers to the hazards posed. by undeclared shipments and to raise in part the awareness of persons like "packagers" in recognizing those threats and taking appropriate measures to assure compliance with the HMR.

If you believe the HMR should be revised to better address requirements for self-propelled vehicles, you may submit a petition for rulemaking as provided in § 106.31. I hope that this information is helpful. If you need further assistance, please contact us.



Thomas G. Allan
Deputy Director
Office of Hazardous Materials Standards



Regulation Sections

Section Subject
173.22 Shipper's responsibility