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Interpretation Response #98-0368 ([Shared Services Group] [Mr. Jere Schumacher])

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

Interpretation Response Details

Response Publish Date:

Company Name: Shared Services Group

Individual Name: Mr. Jere Schumacher

Location State: WA Country: US

View the Interpretation Document

Response text:

JAN 14, 1999


Mr. Jere Schumacher                           Ref No. 98-0368
Boeing Traffic Management
Shared Services Group
P.O. Box 3707
Seattle, Washington 98124-2207

Dear Mr. Schumacher:

This is in response to your letter of December 9, 1998, requesting clarification on the requirements for materials of trade (MOTS) under the Hazardous Materials Regulations (HMR; 49 CFR parts 171 ­I 80).  You presented the following scenario and would like confirmation that the MOTS exception in § 173.6 applies.

An in-house fire company provides fire and safety response, as well as training in these areas.  During the course of these activities some hazardous materials are used.  Fire extinguishers and personal breathing apparatus are moved over public roads to a variety of locations in support of these activities.  They are transported on company owned mobile fire equipment, either to or from an emergency, storage or training location.

The scenario you present is suitable for the MOTS exception as long as all provisions of § 173.6 are met.  Cylinders are required to be marked with the proper shipping name and identification number for the hazardous material and labeled as prescribed in the HMR.  In addition, Specificafion 39 cylinders must be marked as required by § 178.65(i). No shipping papers are required for movements of MOTS.

I hope this information is helpful.


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


Regulation Sections

Section Subject
171.8 Definitions and abbreviations