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 #06-0115 ([Waste Technology Services, Inc.] [Ted L. Nebrich, Jr., CHMM, QEP, REM ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Waste Technology Services, Inc.

Individual Name: Ted L. Nebrich, Jr., CHMM, QEP, REM 

Location State: NY Country: US

View the Interpretation Document

Response text:

Jun 23, 2006


Ted L. Nebrich, Jr., CHMM, QEP, REM                 Reference No. 06-0115
Technical Director
Waste Technology Services, Inc.
435 North 2nd Street
Lewiston, NY 14092

Dear Mr. Nebrich:

This is in response to your March 31, 2006 letter asking us to clarify what is meant by “in direct support of a principal business” under the Materials of Trade (MOTs) exceptions prescribed in § 173.6 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you state your company transports environmental samples for your customers to a laboratory, treatment storage and disposal facility (TSDF) for analysis and/or treatability studies or to one location for consolidation arid packaging, and you often perform these tasks as a convenience for your clients.

Under the HMR, one of the defining conditions for MOTs is a hazardous material, other than a hazardous waste, transported by a private motor carrier in direct support of a principal business that is other than transportation by motor vehicle. If a business uses its own vehicles and drivers to transport goods to and from customer locations, then the MOTs exception in § 173.6 may be utilized. Since your principal business is not transportation, you may utilize the MOTs exception to transport environmental samples. Note, however, that if you hire a motor carrier to transport goods to and from customer locations, the MOTs exception does not apply.

I hope this information is helpful.



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


Regulation Sections

Section Subject
173.6 Materials of trade exceptions