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Interpretation Response #01-0299 ([URS Corporation] [Mr. Andrew N. Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew N. Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

DEC 18, 2001


Mr. Andrew N. Romach                           Ref. No. 01-0299
Corporate Regulatory Manager
URS Corporation
1600 Perimeter Park Drive, Suite 100
Morrisville, NC 27560

Dear Mr. Romach:

This is in response to your November 28, 2001 letter requesting clarification on the materials of trade (MOTS) exception found in section § 171.6 of the Hazardous Materials Regulations (HMR; 49 CFR parts 171 -180). Specifically, you ask if an employee from an automobile dealership transports auto parts that meet the definition of a hazardous material to a body shop, would that employee be able to take advantage of the MOTS exception if the transported items meet the inner containment limits in § 173.6.

The described hazardous materials meet the definition for MOTS (§ 171.8). Provided all conditions in § 173.6 are met, the MOTS exception may be applied to your scenario.

I hope this satisfies your request.


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


Regulation Sections

Section Subject
173.6 Materials of trade exceptions