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InstituteMaterials of trade - HazmatInterpretations SpotlightTransportationHazmat SafetyHazmat EdgeHazmatEnglishAnalysisFocus AreaUSA

Materials of trade

Regulation

173.6

Regulation summary

Section 173.6 establishes the general requirements for materials of trade (MOTs) exceptions.

Question/Dilemma

In this scenario, a retail company requests clarification on whether their retail organization’s employees can deliver hazardous materials to their stores and customer locations using private and for-hire vehicles under the MOTs exceptions in 173.6. The items being shipped are for replenishment of inventory or to fulfill an existing sale.

In this interpretation, PHMSA addresses the HMR applicability for MOTs exceptions.

Interpretation summary

In interpretation Ref. No. 06-0075, PHMSA advises that under the HMR, one of the defining conditions for MOTs is a hazardous material, other than a hazardous waste, transported by a private motor carrier in direct support of a principal business that is other than transportation by motor vehicle.

  • If a wholesale business uses its own vehicles and drivers to transport goods to and from customer locations, then the MOTs exception in 173.6 may be utilized.
  • However, if the wholesale company hires a motor carrier to transport goods to and from customer locations, the MOTs exception does not apply.
hazmat
Hazmat
HAZMAT EDGE
InstituteMaterials of trade - HazmatInterpretations SpotlightTransportationHazmat SafetyHazmat EdgeHazmatEnglishAnalysisFocus AreaUSA

Materials of trade

InstituteMaterials of trade - HazmatInterpretations SpotlightTransportationHazmat SafetyHazmat EdgeHazmatEnglishAnalysisFocus AreaUSA

Regulation

173.6

Regulation summary

Section 173.6 establishes the general requirements for materials of trade (MOTs) exceptions.

Question/Dilemma

In this scenario, a retail company requests clarification on whether their retail organization’s employees can deliver hazardous materials to their stores and customer locations using private and for-hire vehicles under the MOTs exceptions in 173.6. The items being shipped are for replenishment of inventory or to fulfill an existing sale.

In this interpretation, PHMSA addresses the HMR applicability for MOTs exceptions.

Interpretation summary

In interpretation Ref. No. 06-0075, PHMSA advises that under the HMR, one of the defining conditions for MOTs is a hazardous material, other than a hazardous waste, transported by a private motor carrier in direct support of a principal business that is other than transportation by motor vehicle.

  • If a wholesale business uses its own vehicles and drivers to transport goods to and from customer locations, then the MOTs exception in 173.6 may be utilized.
  • However, if the wholesale company hires a motor carrier to transport goods to and from customer locations, the MOTs exception does not apply.
Answer
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