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 #09-0021 ([DENSO Manufacturing Tennessee, Inc.] [Mr. Bob Booker])

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

Interpretation Response Details

Response Publish Date:

Company Name: DENSO Manufacturing Tennessee, Inc.

Individual Name: Mr. Bob Booker

Location State: TN Country: US

View the Interpretation Document

Response text:

February 13, 2009




Mr. Bob Booker

Senior Manager, Legal Services and Corporate Compliance

DENSO Manufacturing Tennessee, Inc.

1720 Robert C. Jackson Drive

Maryville, TN 37801-3748

Ref. No. 09-0021

Dear Mr. Booker:

This responds to your January 19, 2009 letter requesting clarification of the use of the materials of trade exceptions under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter, your company transports regulated medical waste (UN3291) between facilities at an industrial park in company-owned and -operated vehicles for the purpose of consolidation of the material at one facility for subsequent pickup and disposal by a separate company. You ask whether you may transport your regulated medical waste as a material of trade.

The answer is yes. It is the opinion of this Office that regulated medical waste transported by your company"s employees in company vehicles in direct support of your business may be transported as a material of trade. In accordance with § 171.8, the definition of a material of trade includes a 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. Therefore, provided the regulated medical waste is packaged in conformance with § 173.6 paragraphs (a)(4) and (a)(4)(ii), and otherwise conforms to the conditions of § 173.6, the regulated medical waste may be transported by your company as a material of trade.

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


Charles E. Betts,

Chief, Standards Development

Office of Hazardous Materials Standards

173.6, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.6 Materials of trade exceptions