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Interpretation Response #04-0145 ([Mobility Products Unlimited, LLC] [Mr. Steven King])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mobility Products Unlimited, LLC

Individual Name: Mr. Steven King

Location State: FL Country: US

View the Interpretation Document

Response text:

Jul 9, 2004


Mr. Steven King                 Reference No. 04-0145
Mobility Products Unlimited, LLC
245 Riverside Drive
Holly Hill, FL 32117

Dear Mr. King:

This is in response to your letter asking for clarification of the materials of trade (MOTs) exceptions under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180). Specifically, you ask for clarification of the term “private motor carrier” as used in the (MOTs) definition in § 171.8. You also ask for clarification of the applicable requirements in § 173.6 for transporting MOTs, including weight limitations and whether registration and shipping paper requirements apply. You state that Mobility Products is a medical equipment provider and will be transporting four 50-pound Division 2.2 compressed oxygen cylinders in a motor vehicle to its customers.

The definition for MOTs in § 171.8 includes a private motor carrier transporting hazardous materials in direct support of a principal business that is other than transportation by motor vehicle. A private motor carrier is a carrier who transports the business’s own products and does not provide such transportation service to other businesses.

In addition to meeting the definition of MOTs in § 171.8, the applicable requirements in § 173.6 must be met. The cylinder must conform to the packaging, qualification, maintenance, and use requirements under the HMR and must be leak tight, securely closed, secured against movement, and protected against damage (see paragraph (b)). A DOT specification cylinder must be marked and labeled in accordance with the HMR (see paragraph (c)(3)), and the operator of the motor vehicle must be informed of the presence of the hazardous material (see paragraph (c)(4)). Paragraph (a)(2) limits a Division 2.2 material in a cylinder to a gross weight not over 220 pounds and paragraph (d) limits the aggregate gross weight of all hazardous materials on one motor vehicle to not more than 440 pounds. With regard to the registration and shipping paper requirements, paragraph (a) states that a hazardous material meeting the MOTs definition in § 171.8 is subject only to the applicable requirements in § 173.6; therefore, such shipments are excepted from the registration and shipping paper requirements.

I hope this information is helpful. Please contact this office should you require additional assistance.




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


Regulation Sections

Section Subject
173.6 Materials of trade exceptions