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.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
Regulation Sections
Section | Subject |
---|---|
173.6 | Materials of trade exceptions |