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PMAA Regulatory Report - June 26, 2014

SUBJECT: U.S. DOT HAZMAT Registration
ISSUE: 2014-2015 HAZMAT Registration Deadline Reminder
PMAA CONTACT: Mark S. Morgan, Regulatory Counsel - mmorgan@pmaa.org
DATE: June 26, 2014

COMPLIANCE REMINDER! U.S. DOT ANNUAL HAZMAT REGISTRATION DEADLINE IS JULY 1

The U.S. DOT’s Pipeline and Hazardous Material Safety Administration (PHMSA) requires all interstate and intrastate marketers transporting petroleum products in placarded vehicles to register and pay an annual HAZMAT fee. Registration is necessary to obtain federal operating authority for the transportation of hazardous materials.  

Registration Deadline: Marketers with expiring HAZMAT registration certificates must register and pay the required fee by July 1, 2014.

Registration Fee: The annual registration fee is $275 for small businesses and $2,600 for large businesses. Most petroleum marketers should qualify for the $275 small business fee (see below).

Registration Process: Online registration is available at http://phmsa.dot.gov/hazmat/registration. Electronic registration allows registrants to download their operating certificate immediately. 

Multi-year Registration: PHMSA allows one, two and three year registrations. As a result, not all current HAZMAT registrants will be required to re-register for the 2014-2015 registration cycle. Marketers should check their HAZMAT registration certificate for the date of expiration before attempting to register for the 2014-2015 registration period.

The following Q & A will assist in compliance:

Q. 1. Who must register and pay the fee?

A. Any business (intrastate or interstate) shipping hazardous materials requiring a U.S. DOT placard must register each year and pay the fee. Petroleum jobbers, common carriers of petroleum products, oil heat dealers and propane suppliers who ship their products in trucks must register and pay the fee.

 Q. 2. What happens if I don’t register?

A. If you fail to register by the deadline then you lose your authority to operate your trucks in both intrastate and interstate commerce. Your authority to operate is the certificate you receive from PHMSA once you register and pay the fee. A current certificate must be kept in the cab of each HAZMAT vehicle at all times. If you are subject to a roadside inspection or DOT audit and do not have a current certificate your authority to operate will be revoked and you could be fined up to $32,500 per day of violation. 

Q. 3. Why is the U.S. DOT collecting the fee? 

A. The money collected from the registration program is given back to state emergency response authorities in the form of training grants for fire and police and emergency preparedness organizations.

 Q. 4. How Do I know my registration is current or not?

 A. Registration status may be checked on line by logging onto:  the DOT.Gov lookup site. Enter either your company name, U.S. DOT number or zip code in the data fields provided to check whether your HAZMAT registration certificate is current.

Q. 5. How do I register?

A. span> There are two ways to register. First you may mail in a paper registration form to PHMSA. A registration form and instructions can be downloaded at http://hazmat.dot.gov/regs/register/register.htm. You may also register online at http://hazmat.dot.gov/regs/register/register.htm. On-line registration allows you to register, pay the fee and download your operating certificate.  

Q. 6. When is the HAZMAT registration deadline? 

A. July 1, 2014 is the registration deadline for all new and expiring hazardous materials registration certificates.

Q. 7. What should I do with registration certificate once I receive it?span> <

A. Keep the original certificate in your files and place a photocopy in the cab of each HAZMAT placarded vehicle by July 1, 2014.

Q. 8. How much is the annual HAZMAT registration fee?:

A. The annual registration fee is based business size. For registration year 2014-2015, the fee for small businesses is $275 for one year; $525 for two years (2014-2016) and $775 for three years (2014-2017). For registration year 2014-2015, the fee for large businesses is $2,600 for one year.

Q. 9. How do I determine the size of my business so I know which fee to pay?

 

A. It is very likely that your business qualifies for the lower registration fee. Determining size is left up to the company applying for the registration certificate. PHMSA follows Small Business Administration (SBA) size categories to classify whether a business is large or small for the purposes of determining the amount of the annual registration fee. The SBA determines business size according to NAICS (North American Industrial Classification System) codes based on either the number of employees in the company or on annual gross receipts. The following NAICS codes and size criteria apply when calculating which fee to pay:

 

NAICS CODE 424710 - Petroleum Bulk Stations or Terminals: Petroleum marketers in this category are considered small businesses and must pay the $275 fee if the company employs fewer than 100 employees.

 

NAICS CODE 424720 - Petroleum and Petroleum Product Wholesalers (no bulk storage): Petroleum marketers in this category are considered small businesses and must pay the $275 fee if the company employs fewer than 100 employees.

 

NAICS CODE 454311 - Heating Oil Dealers:  Heating oil dealers in this category are considered small businesses and must pay the $275 fee if the company employs fewer than 50 employees.

 

NAICS CODE 454312 - Liquefied Petroleum Gas Dealers:  Propane dealers in this category are considered small businesses and must pay the $275 fee if the company employs fewer than 50 employees.

 

Q. 10. What if I registered as a large business but now I qualify for the small business fee?

 

A. If your business circumstances have changed and you now qualify for small business status under the HAZMAT registration fee, call Mark S. Morgan at (202) 364-6767 for further instructions.

 

Q. 11. Where can I get more information?

 

A. Contact Mark S. Morgan, PMAA Regulatory Counsel at (202) 364-6767 or mmorgan@pmaa.org.


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