Explosives by highway: Lining of a motor vehicle
Pipeline and Hazardous Materials Safety Administration · Oct 16, 2007 · Reference No. 07-0164
Interprets: 49 CFR § 177.835
Reggie’s quick take
Someone asked whether a truck bed lining made from spray-on polyurethane meets the lining rules in § 177.835(f) for highway transport of explosives. The agency's answer is yes, but only for Division 1.1, 1.2, or 1.3 explosives, and only if the lining is non-metallic or non-ferrous and meets the rest of § 177.835. The agency says there is no similar provision for Division 1.4 explosives.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your August 29, 2007 email regarding the transportation of explosives by highway under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
In your letter, you ask whether a truck bed lining manufactured from a spray-on polyurethane coating meets the requirements for a lining of a motor vehicle transporting Division 1.3G or 1.4G (explosive) materials as specified in § 177.835(f) of the HMR.
Paragraph (f) of § 177.835 specifies the requirements for the lining of a motor vehicle transporting Division 1.1, 1.2, or 1.3 (explosive) materials by highway. It is the opinion of this Office that provided it consists of either non-metallic material or non-ferrous materials and complies with the remainder of the requirements in § 177.835, a truck bed lining manufactured from a spray-on polyurethane is an acceptable lining for a motor vehicle transporting Division 1.1, 1.2, or 1.3 (explosive) materials by highway. There is no similar provision for the lining of a motor vehicle transporting Division 1.4 (explosive) materials by highway.
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.