DOT's Research and Special Programs Administration (RSPA) has clarified hazmat rules, reiterating that these materials apply to a carrier's possession from pickup through delivery, including loading or unloading. (See Federal Register, October 30, 2003.)
RSPA now defines “pre-transportation function” as any function “required to assure the safe transportation of a hazardous material in commerce,” such as loading packages or containerized hazmat into a vehicle or loading bulk materials.
“Loading incidental to movement” is defined as “loading of packaged or containerized hazmat into a vehicle by carrier personnel or in the presence of carrier personnel.” “Storage incidental to movement” is storage of a transport vehicle, freight container or package containing hazmat between the time a carrier takes physical possession until the hazmat is delivered to the destination.
