In an earlier article I reviewed the operations and activities that are subject to the Hazardous Material Regulations (HMR) of the PHMSA/USDOT. Among other criteria, 49 CFR 171.1 indicates the HMR is applicable to a person who performs a Pre-Transportation Function and any one of the following:
- Offers a hazardous material for transportation in commerce.
- Transports a hazardous material in commerce.
- Causes a hazardous material to be transported in commerce.