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Interpretation Response #08-0064 ([Saybolt LP] [Mr. Mike Conroy])

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

Interpretation Response Details

Response Publish Date:

Company Name: Saybolt LP

Individual Name: Mr. Mike Conroy

Location State: TX Country: US

View the Interpretation Document

Response text:

June 27, 2008

Mr. Mike Conroy

Saybolt LP

6316 Windfern

Houston, TX 77040

Ref. No. 08-0064

Dear Mr. Conroy:

This responds to your March 7, 2008 letter requesting clarification of the applicability of the materials of trade (MOTs) exceptions under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). You state that your company is a licensed public gauger and accredited laboratory serving the petroleum and petro-chemical industry. The primary business of your company is sample collection and analysis of products and samples for your clients. This includes the transport of small amounts of hazardous materials in your company vehicles between laboratories and off-site job locations. 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 laboratories and off-site locations.

I hope this information is helpful. Please contact us if you require additional assistance.



Susan Gorsky

Regulations Officer

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.6 Materials of trade exceptions