Interpretation Response #03-0299 ([Gram Safety Services] [Mr. Urns Gram])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Gram Safety Services
Individual Name: Mr. Urns Gram
Location State: CO Country: US
View the Interpretation Document
Response text:
Oct 19, 2004
Mr. Urns Gram Reference No. 03-0299
Gram Safety Services
59285 Lotus Court
Montrose, CO 81401
Dear Mr. Gram:
This is in response to your November 10, 2003 letter regarding the materials of trade exception under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a medical home health care supplier may transport oxygen cylinders, each weighing less than 100 kg (220 pounds), as a materials of trade in accordance with § 173.6. Please accept my apology for our delay in responding to your letter.
The answer is yes. Based on the information provided, delivery of oxygen cylinders is
not the principal business for the home health care supplier and supplying patients with oxygen cylinders is in direct support of its business. Therefore, the oxygen cylinders carried on the health care supplier’s vehicle meet the definition of a material of trade in § 171.8 and may be transported under the conditions specified in § 173.6.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
Hattie Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
171.8, 173.6
Regulation Sections
Section | Subject |
---|---|
171.8 | Definitions and abbreviations |
173.6 | Materials of trade exceptions |