• MOTs are hazardous materials carried on a motor vehicle to protect the vehicle’s occupants, support the vehicle’s operation, or support a business that is not motor transport (e.g., lawn care).
• MOTs are excepted from some HMR requirements such as shipping papers and placarding but must be packaged and labeled as specified in 173.6.

Materials of trade (MOTs) are hazardous materials that are carried on a motor vehicle:

• To protect the health and safety of the vehicle operator or passengers (such as insect repellant or self-contained breathing apparatus);
• To support the operation or maintenance of the vehicle, including its auxiliary equipment (such as a spare battery, gasoline, or engine starting fluid); or
• By a private motor carrier (including vehicles operated by a rail carrier) in direct support of a principal business other than transportation by motor vehicle (such as lawn care, plumbing, welding, or painting operations). (171.8)

Hazard and Size Limitations

A material of trade (not including self-reactive material, poisonous by inhalation material, or hazardous waste) is limited to:

1. A Class 3, 8, 9, Division 4.1, 5.1, 5.2, 6.1, or ORM-D material contained in a packaging having a gross mass or capacity not over—
   • 1 pound (0.5 kg) or 1 pint (0.5 L) for Packing Group I material,
   • 66 pounds (30 kg) or 8 gallons (30 L) for a Packing Group II, III, or ORM-D material,
   • 400 gallons (1500 L) for a diluted mixture, not to exceed 2 percent concentration, of a Class 9 material;
2. A Division 2.1 or 2.2 material in a cylinder with a gross weight not over 220 pounds (100 kg);
3. A Division 2.1 or 2.2 material in a Dewar flask meeting the requirements in Section 173.320;
4. A non-liquefied Division 2.2 material with no subsidiary hazard in a permanently mounted tank manufactured to the ASME Code at not more than 70 gallons water capacity;
5. A Division 4.3 material in Packing Group II or III contained in a packaging having a gross capacity not exceeding 1 ounce (30 mL);
6. A Division 6.2 material, other than a Category A infectious substance, contained in human or animal samples being transported for research, diagnosis, investigational activities, or disease treatment or prevention or is a biological product or regulated medical waste.
   • The material must be contained in a combination packaging. For liquids the inner packaging must be leakproof, and the outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packaging.
   • For sharps, the inner packaging must be constructed of a rigid material resistant to punctures and securely closed to prevent leaks or punctures, and the outer packaging must be securely closed to prevent leaks or punctures.
   • For solids, liquids, and sharps, the outer packaging must be a strong, tight packaging securely closed and secured against movement, including relative motion between packages, within the vehicle on which it is being transported.
   • For other than regulated medical waste, the amount of Division 6.2 material in a combination packaging must be in:
     • One or more inner packagings, each of which may not contain more than 1.1 pounds (0.5 kg) or 17 ounces (0.5 L), and an outer packaging containing not more than 8.8 pounds (4 kg) or 1 gallon (4 L); or
     • A single inner packaging containing not more than 35.2 pounds (16 kg) or 4.2 gallons (16 L) in a single outer packaging.
7. For regulated medical waste, a combination packaging must consist of one or more inner packagings, each of which may not contain more than 8.8 pounds (4 kg) or 1 gallon (4 L), and an outer packaging containing not more than 35.2 pounds (16 kg) or 4.2 gallons (16 L);
8. A limited quantity package prepared in accordance with the regulations. Class 7 (radioactive) substances, instruments, and articles are not authorized.
9. For a material or article that does not have a packing group in column 5 of the Hazardous Materials Table: for classes identified in item 1 above, the amounts specified there; and for Division 4.3 materials, packaging having a gross capacity not exceeding 30 mL.

Gross weight

The gross weight of all MOTs on a motor vehicle may not exceed 440 pounds (200 kg), not including 400 gallons (1,500 L) or less of a diluted mixture of Class 9 material, as mentioned above. (173.6)

Markings

A non-bulk packaging, other than a cylinder, must be marked with a common name or proper shipping name to identify the material it contains (such as spray paint or isopropyl alcohol).

If the packaging contains a reportable quantity of a hazardous substance, the letters “RQ” must be included.

A bulk packaging containing a diluted mixture (≤2%) of a Class 9 material must be marked on two opposing sides with the identification number. (173.6)

Packagings

Packaging for MOTs must be leak tight for liquids and gases; sift proof for solids; and securely closed, secured against shifting, and protected against damage. Each material must be packaged in the manufacturer’s original packaging or a packaging of equal or greater strength and integrity. Packaging for gasoline must be made of metal or plastic and conform to the Hazardous Materials Regulations (HMR) or Occupational Safety & Health Administration (OSHA) regulations.

Outer packagings are not required for receptacles (e.g., cans and bottles) or articles that are secured against shifting in cages, carts, bins, boxes, or compartments, or by other means. (173.6)

Cylinders

A cylinder or other pressure vessel containing a Division 2.1 or 2.2 material must conform to the marking, labeling, packaging, qualification, maintenance, and use requirements of the HMR, except that outer packagings are not required. Manifolding of cylinders is authorized provided all valves are tightly closed. (173.6)

Drivers

The operator of a motor vehicle that contains MOTs must be informed of the presence of the material and must be informed of the MOTs requirements in HMR section 173.6.

Exceptions

The MOTs regulations do not require:

• Shipping papers,
• Emergency response information,
• Placarding,
• Formal hazmat training, or
• Retention of training records.

The MOTs regulations do require:

• General knowledge of the regulations,
• Quantity limitations,
• Packaging requirements,
• Marking requirements,
• Labeling requirements,
• Closure requirements, and
• Securement requirements. (173.6)