PHMSA letter of interpretation

Applicability of Hazardous Materials Registration Program

Pipeline and Hazardous Materials Safety Administration · Aug 16, 2000 · Reference No. 00-0200

PHMSA says to use caution with this letter.

Interprets: 49 CFR § 107.601

This is in response to your letter dated July 21, 2000, concerning the applicability of the Hazardous Materials Registration Program as specified in 49 CFR Part 107, Subpart G. Specifically, you ask if your company must register in order to fabricate specification packagings authorized under Part 178, Subpart L.

Since you do not perform any functions of a shipper or carrier and do not engage in any of the activities specified in 107.601, you are not required to register.

A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.