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Are motor vehicles being transported considered to be HM for purposes of the financial responsibility requirements, thus requiring the higher limits set forth in the regulations?

Document

Part 387

Section § 387.3: Applicability.

Guidance Q&A

Question 8: Are motor vehicles being transported considered to be HM for purposes of the financial responsibility requirements, thus requiring the higher limits set forth in the regulations?

Guidance: Yes. Even though vehicles being transported by motor vehicle are subject only to 49 CFR 173.220 of the HMRs, they meet the definition of “Hazardous material” in 49 CFR 171.8 because “Vehicle, flammable gas powered” and “Vehicle, flammable liquid powered” are designated as hazardous in 49 CFR 172.101 [UN 3166]. For that reason, vehicles transporting other vehicles would have to carry $1,000,000 of public liability insurance.

Regulatory Topic: Whether motor vehicles being transported are considered hazardous materials for purposes of the financial responsibility requirements
Effective Date: Friday, February 28, 2020
Issued Date: Friday, February 28, 2020