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Interpretation Response #00-0141 ([Merichern Company Research Center] [Mr. Leo N. Richard Jr.])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Merichern Company Research Center

Individual Name: Mr. Leo N. Richard Jr.

Location State: TX Country: US

View the Interpretation Document

Response text:

June 28, 2000

Mr. Leo N. Richard Jr.               Ref. No. 00-0141
Chemical Hygiene Supervisor
Merichern Company Research Center
1503 Central
Houston, Texas 77012-2797

Dear Mr. Richard:

This is in response to your letter of May 2, 2000, requesting clarification on the requirements for
Materials of Trade (MOTs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -
180). You provide the following scenario and ask whether the MOTs exception may be applied.

From time to time "samples" must be transported to an independent analytical laboratory for various analyses.  Could a Merichem Research Center employee transport the samples to the laboratory?  After analyses are completed, could a Merichern employee transport the samples back to the Merichem Research Center?  All requirements in §173.6 are met.

The answer is yes.  A Merichern Research Center employee may transport samples to and from a laboratory in direct support of their business when in private carriage.

I hope this information is helpful.


Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.6 Materials of trade exceptions