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Interpretation Response #01-0220 ([Williams Laboratory Services] [Ms. Jan Johnson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Williams Laboratory Services

Individual Name: Ms. Jan Johnson

Location State: KS Country: US

View the Interpretation Document

Response text:

September 17, 2001


Ms. Jan Johnson                                 Reference No. 01-0220
Supervisor of Business Operations
Williams Laboratory Services
1090-A Sunshine Road
Kansas City, Kansas 66115

Dear Ms. Johnson:

This is in response to your August 21, 2001 letter requesting clarification of the definition for “Materials of Trade” under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180).  Specifically you ask if hazardous materials transported between your company’s facility and a laboratory for testing purposes, may be considered materials of trade.

One criterion for a material of trade is that a hazardous material is transported by a private carrier in direct support of its principal business which may not be transportation by motor vehicle.  Provided all conditions of § 173.6 are met, the materials of trade exception may be applied in your scenario.

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