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Interpretation Response #14-0115 ([Midwest Veterinary Supply, Inc.] [Ms. Joanne Kittridge])

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

Interpretation Response Details

Response Publish Date:

Company Name: Midwest Veterinary Supply, Inc.

Individual Name: Ms. Joanne Kittridge

Location State: MN Country: US

View the Interpretation Document

Response text:

March 19, 2015

Ms. Joanne Kittridge
Midwest Veterinary Supply, Inc.
21467 Holyoke Avenue
Lakeview, MN 55044

Ref. No. 14-0115

Dear Ms. Kittridge:

This is a response to your May 22, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the materials of trade (MOTs) exception under § 173.6. We apologize for the delay in responding and any inconvenience this may have caused. In your email, you describe delivering hazardous materials (hazmat) products, such as ORM-D products both between your company’s warehouse facilities and to veterinary clinics using your company’s vehicles and drivers. Specifically, you request clarification on whether the products, which are not for company use, are eligible to be transported under the MOTs exception.

The answer is yes. Under the HMR, one of the defining conditions for a MOT is that it is a hazardous material, other than a hazardous waste, transported by a private motor carrier in direct support of a principal business that is other than transportation by motor vehicle. If a wholesale business uses its own vehicles and driver(s) to transport goods to and from customer locations or their warehouses, then the MOTs exception in § 173.6 may be utilized if the quantity limitations in § 173.6(a) are not exceeded and the aggregate gross weight of all MOTs on a motor vehicle is not more than 200 kg (440 pounds). Note, however, that if the wholesale company hires a motor carrier to transport goods to and from customer locations, the MOTs exception does not apply.

I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office.

Sincerely,

Dirk Der Kinderen
Acting Chief, Standards Development
Standards and Rulemaking Division

173.6, 173.6(a)

Regulation Sections

Section Subject
173.6 Materials of trade exceptions