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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0287 ([Mr. Andy Altemos])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Andy Altemos

Location State: DC Country: US

View the Interpretation Document

Response text:

November 9, 2000

Mr. Andy Altemos                Ref No. 00-0287
1850 K Street, N.W.
Suite 200
Washington, D.C. 20006-3500

Dear Mr. Altemos:

This is in response to your October 6, 2000 letter regarding the materials of trade (MOTS) exception as it applies to the transport of certain hazardous materials by motor vehicle in support of aircraft maintenance operations, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You provided the following scenario and asked whether your understanding is correct that the MOTS exception would apply in the scenario described below:

An airline uses motor vehicles to transport hazardous materials in support of aircraft maintenance operations.  The airline would operate these vehicles as a private motor carrier in direct support of a principal business that is other than transportation by motor vehicle.  Hazardous materials transported over public highways in connection with an airline's aircraft maintenance operations include, but are not be limited to, the movement DE

1)      Materials from one warehouse to another warehouse;

2)      Materials from a maintenance facility or warehouse to an airport where maintenance operation
         are performed on an aircraft; and

3)      Samples to or from a laboratory for analysis.

One criterion for using the material of trade exception, as defined in ' 171.8, is that a hazardous material be transported by a private carrier in direct support of its principal business, which may not be transportation by motor vehicle.  Based on the scenario presented and provided all conditions of ' 173.6 are met, an airline performing private carriage by highway may transport hazardous materials under the MOTS exception.

I hope this satisfies your inquiry.



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



Regulation Sections

Section Subject
173.6 Materials of trade exceptions