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Interpretation Response #98-0038 ([Digital Audio Disc Corporation] [Mr. Gary J. Garrahan])

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

Interpretation Response Details

Response Publish Date:

Company Name: Digital Audio Disc Corporation

Individual Name: Mr. Gary J. Garrahan

Location State: IN Country: US

View the Interpretation Document

Response text:

JUL 9, 1998


Mr. Gary J. Garrahan                     Ref.  No: 98-0038
Environmental Engineer
Digital Audio Disc Corporation
P.O. Box 3710
Terre Haute, Indiana 47803-0710

Dear Mr. Garrahan:

This is in response to your letter of April 30, 1998, requesting clarification of the materials of trade (mots) exception provide in the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180).  You presented the following scenario:

Your manufacturing operations consist of two buildings separated by a road with public access. Occasionally you may have a need to transport a small quantity (e.g., 1 gallon of a class 3, PG II material) from one building to the other.
This is not a normal business practice, it would occur only when necessary.  The material is transported by a private carrier and is used to directly support your manufacturing process.

The above scenario qualifies for transportation as MOTs provided all requirements in 173.6 are met.

I hope this satisfies your request.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
173.6 Materials of trade exceptions