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Interpretation Response #12-0060 ([Bombardier Aerospace] [Mr. Jeff Christafore])

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

Interpretation Response Details

Response Publish Date:

Company Name: Bombardier Aerospace

Individual Name: Mr. Jeff Christafore

Location State: WV Country: US

View the Interpretation Document

Response text:

April 19, 2012




Mr. Jeff Christafore
Dangerous Goods Compliance Specialist
Bombardier Aerospace
2400 Aviation Way
Bridgeport, WV 26330

Reference No.: 12-0060

Dear Mr. Christafore:

This is in response to your February 24, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to materials of trade (MOTs) exceptions. You describe a scenario in which a mobile repair party transports parts and materials, belonging to hazard classes 2.2 and 9, needed to repair an aircraft off-site. Specifically you ask if use of the MOTs exception is limited to items used to service, or if the MOTs exception can be utilized for replacement parts.

The HMR makes no distinction between hazardous materials used to service and hazardous materials being utilized for replacement parts. The definition of MOTs in § 171.8 contains three separate conditions, if one of these conditions is meet, and your shipment meets the conditions of § 173.6, you may utilize the MOTs exception. Your shipments meet the third condition in the definition of MOTs, "by a private motor carrier in direct support of a principal business that is other than transportation by motor vehicle".

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

171.8, 173.6

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.6 Materials of trade exceptions