The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) responded in a March 15th letter to a May 9, 2016 question requesting clarification of the Hazardous Materials Regulations (“HMR”) applicable to agricultural shipments of hazardous materials.

The question was posed by the Iowa Office of Motor Vehicle Enforcement (“Iowa”). The questions (paraphrasing) posed by Iowa include:

(1.) Does § 173.5(a) limit the package size of shipments transported between fields?

PHMSA states there are no limits to the size of the package provided all applicable provisions in § 173.5(a) are met for transportation over local roads between fields of the same farm.

(2.) Does § 173.5(a) limit the distance hazardous materials can be transported between fields?

PHMSA states there are no limits to the distance the package can travel provided all applicable provisions in § 173.5(a) are met for transportation over local roads between fields of the same farm.

(3.) Is § 173.5(b) a standalone provision, therefore not affecting the applicability of § 173.5(a)?

PHMSA states that § 173.5(a) applies to agricultural products being transported between fields of the same farm on local roads. Further noting:

. . .the roads that connect fields of the same farm are considered local roads and not public roads. § 173.5(b) applies to agricultural products being transported to and from a farm within 150 miles of a farm and within the scope of the authorized mileage.

A copy of the letter can be downloaded here.