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Interpretation Response #08-0044 ([Inspecorate America Corporation] [Mr. John E. Williams III])

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

Interpretation Response Details

Response Publish Date:

Company Name: Inspecorate America Corporation

Individual Name: Mr. John E. Williams III

Location State: TX Country: US

View the Interpretation Document

Response text:

June 27, 2008

Mr. John E. Williams III

Director HSE

Inspectorate America Corporation

12000 Aerospace Avenue, Suite 200

Houston, TX 77034-5576

Ref. No. 08-0044

Dear Mr. Williams:

This responds to your February 15, 2008 letter, requesting clarification on the materials of trade (MOTs) exception under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter, your company transports samples from chemical and petroleum refineries and marine terminals to your laboratories and facilities. Additionally, you transport and use small amounts of solvents to conduct wall wash tests on marine vessels. The run off of the wash is collected and analyzed to determine the presence of any contaminants prior to loading other chemicals or petroleum products. You request confirmation that these activities performed by your non transportation-related company qualify for the MOTs exception. You ask whether the MOTs exceptions under §173.6 of the HMR apply to the hazardous materials transported by your company.

The answer is yes. The HMR define a MOT as hazardous material, other than a hazardous waste, that is carried on a motor vehicle by a private motor carrier in direct support of a principal business that is other than transportation by motor vehicle. Provided all requirements of §173.6 are met, you may utilize the MOTs exceptions for the transportation of hazardous materials between your laboratories and facilities and off-site locations.

I hope this answers your inquiry.

Sincerely,

Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards

173.6

Regulation Sections

Section Subject
173.6 Materials of trade exceptions