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U.S.-Canada Materials of Trade/150 kg gross mass exemption Comparison Chart

This chart compares the U.S. materials of trade exception to Canada’s 150 kilogram gross mass exemption.

United StatesCanada
RegulationMaterial of trade (MOT) exception
49 CFR 171.8 (definition of material of trade) and 173.6 (requirements)
150-kilogram (330-pound) Gross Mass Exemption
Transportation of Dangerous Goods (TDG) Regulations, (SOR/2001-286), Section 1.
ApplicabilityMaterials 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;
● To support the operation or maintenance of the vehicle, including its auxiliary equipment; 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.
The dangerous goods must be in a quantity or concentration available to the general public and transported:
● By a user or purchaser of the dangerous goods, or
● By a retailer to or from a user or purchaser of the dangerous goods.
Quantity limits, non-gases● Class 3, 8, 9, Division 4.1, 5.1, 5.2, 6.1, or ORM-D material in a packaging having a gross mass or capacity not over
1. 1 pound (0.5 kg) or 1 pint (0.5 L) for Packing Group I material,
2. 66 pounds (30 kg) or 8 gallons (30 L) for a Packing Group II , III , or ORM-D material,
3. 400 gallons (1500 L) for a diluted mixture, not to exceed 2% concentration, of a Class 9 material;
● 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).
● 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.1
● A limited quantity package prepared in accordance with the regulations.
● For a material or article that does not have a packing group: for classes identified in the first bullet above, the amounts specified there; and for Division 4.3 materials, packaging having a gross capacity not exceeding 30 mL.
Contained in one or more means of containment each of which has a gross mass less than or equal to 30 kg (66 pounds).
Applicability, gases● Division 2.1 or 2.2 material in a cylinder with a gross weight not over 220 pounds (100 kg)
● A Division 2.1 or 2.2 material in a Dewar flask meeting the requirements in Section 173.320
● 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
● Dangerous goods included in Class 2, Gases, in one or more small means of containment in compliance with the requirements for transporting gases in Part 5 (Means of Containment), except that, in the case of dangerous goods that are UN1950, AEROSOLS, or UN2037, GAS CARTRIDGES, the requirement in section 8.1.7 of CGSB-43.123 that aerosol containers and gas cartridges be tightly packed in a strong outer packaging does not apply, or
● Class 2.1, Flammable Gases, must be in a cylinder with a capacity of 46 L or less
Gross weight limitThe 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 The gross mass of all dangerous goods:
● Transported on the road vehicle or the railway vehicle is less than or equal to 150 kilograms (330 pounds); and
● Transported on the vessel on a domestic voyage is less than or equal to 150 kilograms (330 pounds), excluding dangerous goods in a road vehicle or railway vehicle being transported on the vessel
Materials not allowed under the exception● Class 1
● Self-reactive hazardous materials
● Poisonous by inhalation hazardous materials
● Hazardous wastes
● Class 7 (radioactive) substances, instruments, and articles
● Dangerous goods that require an Emergency Response Assistance Plan (ERAP)
● Dangerous goods that require a control or emergency temperature
● Are included in Class 1, Explosives, except for UN numbers UN0012, UN0014, UN0044, UN0055, UN0105, UN0131, UN0161, UN0173, UN0186, UN0191, UN0197, UN0276, UN0312, UN0323, UN0335 if classified as a consumer firework, UN0336, UN0337, UN0351, UN0373, UN0378, UN0404, UN0405, UN0431, UN0432, UN0454, UN0499, UN0501, UN0503, UN0505 to UN0507, UN0509, and UN0510 • Class 2.1, Flammable Gases, in a cylinder with a capacity greater than 46 L
● Class 2.3, Toxic Gases
● Class 4, Flammable Solids; Substances Liable to Spontaneous Combustion; Substances that on Contact with Water Emit Flammable Gases (Water-reactive Substances); and in Packing Group I
● Class 5.2, Organic Peroxides, unless they are allowed to be transported as limited quantities
● Class 6.1, Toxic Substances, and Packing Group I
● Class 6.2, Infectious Substances
● Class 7, Radioactive Materials, and are required to be licensed by the Canadian Nuclear Safety Commission.
Packaging● 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.
● Packaged in the manufacturer’s original packaging or a packaging of equal or greater strength and integrity.
● Gasoline must be in 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.
● 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.
Dangerous goods in one or more small means of containment designed, constructed, filled, closed, secured and maintained so that under normal conditions of transport, including handling, there will be no accidental release of the dangerous goods that could endanger public safety
Markings, Labels, and PlacardsA 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.
Part 4, Dangerous goods safety marks, is not applicable.
Driver trainingFormal training not required; drivers must be aware of MOT regulation and that MOT are present on the vehiclePart 6, Training, is not applicable.
1The 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 (sharps container) 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 shifting, including relative motion between packages, within the vehicle on which it is being transported.
(i) For other than a regulated medical waste, the amount of Division 6.2 material in a combination packaging must conform to the following limitations:
(A) One or more inner packagings, each of which may not contain more than 0.5 kg (1.1 lbs) or 0.5 L (17 ounces), and an outer packaging containing not more than 4 kg (8.8 lbs) or 4 L (1 gallon); or
(B) A single inner packaging containing not more than 16 kg (35.2 lbs) or 16 L (4.2 gallons) in a single outer packaging.
(ii) For a regulated medical waste, a combination packaging must consist of one or more inner packagings, each of which may not contain more than 4 kg (8.8 lbs) or 4 L (1 gallon), and an outer packaging containing not more than 16 kg (35.2 lbs) or 16 L (4.2 gallons).