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.
Sincerely,
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 |