Shipper's Certification
Pipeline and Hazardous Materials Safety Administration · Jan 24, 1995 · Reference No. 95-0107
Interprets: 49 CFR § 172.24, 49 CFR § 172.204, 49 CFR § 176.27, 49 CFR § 177.817
Reggie’s quick take
A shipper asked whether carriers must get a signed shipper's certification for hazmat moved by highway, rail, or vessel. The agency says the first highway or rail carrier must get a signed certification before accepting the shipment, but later highway carriers and train crews do not need it. A vessel operator may not carry hazmat unless it gets a signed certification (§ 176.27). If the cargo moves by highway, rail, and then vessel, both the highway carrier and the vessel operator must get one. If the cargo goes to a vessel operator for later rail and highway legs, only the vessel operator must receive it.
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 inquiry concerning requirements for carriers to receive a shipper's certification prepared in accordance with 49 CFR 172.204 for transportation by highway, rail, or vessel.
You are correct in your understanding of the regulations. An initial highway or rail carrier is required to obtain a signed shipper certification as specified in § 177.817(b) or § 174.24(a), respectively, prior to accepting a hazardous materials shipment, but is not required to provide any subsequent highway carrier or train crew with shipping documents containing a shipper's certification.
A vessel operator may not transport a hazardous material shipment unless provided a signed shipper certification, as specified in § 176.27. Therefore, if a hazardous material shipment is offered for transportation and transported by highway, rail, and vessel, respectively, both the highway carrier and the vessel operator must obtain shipping documents containing a signed shipper's certification. However, if a shipper offers a hazardous material shipment to a vessel operator for subsequent transportation by rail and highway, only the vessel operator is required to receive the shipper's certification.
I trust this response satisfies your inquiry. Please do not hesitate to contact this office if you require additional assistance.
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.