Comments onU.S. DOT Current and Important Interpretation of the Hazardous Materials Regulations

摘要

While specifically addressing the responsibilities for inspection of tank cars prior to offering the cars for transport, this letter sheds light on the rather complex issue of shipper's responsibilities in the context of the relatively common practice in which a chemical supplier completes and executes shipping papers for the return from customer's facilities of tank cars containing a residue of hazardous material. Note that DOT advises that once the questioner elected to prepare the shipping papers, it became the "offerer" and was responsible for the performance of other offerer functions required by the HMR (for example, inspection of the tank cars prior to their offering) - even though the questioner was not in physical possession or control of the cars.