USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

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.



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