Transportation of PIH Materials
Pipeline and Hazardous Materials Safety Administration · Aug 5, 1999 · Reference No. 99-0109
Interprets: 49 CFR § 173.227
Reggie’s quick take
A company asked whether it could deliver a zone B inhalation hazard product to two plants owned by the same company, with the truck unloading at the first plant and then driving four hours to unload the rest at the second. PHMSA said no. Under § 173.227(c), shipments of these materials must go from one origin to one destination only, with no intermediate pickup or delivery, and a route with two delivery points does not meet that rule.
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 letter dated April 20, 1999, regarding the transportation of materials poisonous by inhalation in accordance with 49 CFR 173.227(c). I am sorry for the delay and hope this has not caused you any inconvenience.
In your letter you ask if the following situation meet the conditions of the last sentence of § 173.227(c):
I am contemplating a situation where I want to make deliveries of an inhalation hazard (zone B) product to two different locations of the same company. The truck would stop at one plant, unload the containers for that plant, and then proceed to the second plant (four hours away) where the remaining containers would be unloaded.
The last sentence of § 173.227(c) states that "shipments must be made from one origin to one destination only without any intermediate pickup or delivery." It is the opinion of this office that the scenario presented in your letter does not meet the conditions of § 173.227(c) because your shipment scenario involves more than one delivery point.
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.