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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #10-0234 ([Kelly Infinity] [Mr. Jeff Brown])

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

Interpretation Response Details

Response Publish Date:

Company Name: Kelly Infinity

Individual Name: Mr. Jeff Brown

Location State: MA Country: US

View the Interpretation Document

Response text:

December 22, 2010



Mr. Jeff Brown

Kelly Infinity

155 Andover Street

Danvers, MA 01923

Ref. No. 10-0234

Dear Mr. Brown:

This responds to your October 29, 2010 request for clarification on the materials of trade (MOT) exception under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter, your company is a small auto dealership that delivers a small quantity of Class 9 items, e.g., seat belts/air bags by your own van, along with other auto parts. You ask if these activities performed by your non transportation-related company qualify for the MOT exception.

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 MOT exception for the transportation of the Class 9 materials, including seat belts/air bags.

I hope this answers your inquiry. If you need additional assistance, please contact this Office at 202-366-8553.


Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division


Regulation Sections

Section Subject
173.6 Materials of trade exceptions