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 #06-0090 ([Target Specialty Products] [Mr. Gary Maxwell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Target Specialty Products

Individual Name: Mr. Gary Maxwell

Location State: CA Country: US

View the Interpretation Document

Response text:

Jun 15, 2006


Mr. Gary Maxwell                 Reference No. 06-0090
Target Specialty Products
15415 Marquardt Avenue
Santa Fe Springs, CA 90670-5711

Dear Mr. Maxwell:

This is in response to your April 13, 2006 letter regarding the Materials of Trade exception under § 173.6 of the Hazardous Materials Regulations (HMR; 49 CFR Parts
171-180). Specifically, you ask if a hazardous material transported under the Materials of Trade exception may be transported (when originally packaged in combination packaging) without the strong outer packaging provided by the manufacturer.

The answer is yes. Under § 173.6(b)(3) outer packagings are not required for receptacles (e.g., cans and bottles) that are secured against shifting in cages, carts, bins, boxes or compartments. A cylinder or other pressure vessel (e.g., an aerosol can) containing a Division 2.1 or 2.2 material must conform to packaging, qualification, maintenance, and use requirements of this subchapter, except that outer packagings are not required. Packaging for materials of trade must be the manufacturer’s original packaging a packaging of equal or greater strength and integrity.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



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

171.8, 173.6 (b)(3)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.6 Materials of trade exceptions