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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 #02-0228 ([PPL Technical Training Center] [Frederick A.Muthard])

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

Interpretation Response Details

Response Publish Date:

Company Name: PPL Technical Training Center

Individual Name: Frederick A.Muthard

Location State: PA Country: US

View the Interpretation Document

Response text:

Sep 27, 2002

Mr. Frederick A. Muthard                     Reference No. 02-0228
PPL Technical Training Center
1639 Church Road
Allentown, PA 18104-9342

Dear Mr. Muthard:

This is in response to your letter requesting clarification of the materials of trade (MOTs) requirements under
§ 173.6 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:

Q1. Do the quantities listed in § 173.6(a) apply to each packaging or to a particular hazard class or division?

A1. Except for a MOT authorized by §173.6(a)(1)(iii), the quantity limits in § 173.6(a) are the maximum allowable quantity per packaging.  Using your example, the maximum allowable quantity for a Class 3 Packing Group II material is 8 gallons per packaging.

Q2. May multiple packagings of MOTs be transported on the same motor vehicle provided the aggregate gross weight is not exceeded?

A2. Yes, two or more packagings of hazardous materials may be transported under the MOTs exception provided all conditions of § 173.6 are met and the aggregate gross weight does not exceed 440 pounds.

Q3. Can we transport hazardous materials using the MOTs exception between our company's facilities?

A3. If the hazardous material meets the definition in § 171.8 of a Material of trade, the answer is yes.

Q4. Are there additional Federal regulations that apply when MOTS are transported across state lines?

A4. No. The HMR apply to the transportation of hazardous materials in interstate, intrastate and foreign commerce.

I trust this satisfies your inquiry.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.6 Materials of trade exceptions