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Interpretation Response #98-0503 ([United Surveyors of Chemicals, Inc.] [Mr. Jeffrey M. Moses])

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

Interpretation Response Details

Response Publish Date:

Company Name: United Surveyors of Chemicals, Inc.

Individual Name: Mr. Jeffrey M. Moses

Location State: TX Country: US

View the Interpretation Document

Response text:

FEB 23, 1998


Mr. Jeffrey M. Moses
CMTS Director of Services
United Surveyors of Chemicals, Inc.
P.O. Box 3555
Baytown, Texas 77522-3555

Dear Mr. Moses:

This is in response to your letter of January 13, 1998, regarding transportation of small quantities of chemicals transported by your business under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). You state that your company is a licensed public gauger and accredited laboratory which serves the chemical industry. Your primary business is analyzing products for customers using small amount of hazardous materials in the process. Additionally, you may transport small amounts of hazardous materials that you use to wash the walls of ships and analyze the run off to determine amounts of contamination. You ask whether the hazardous materials you use to perform these analyses may be considered Materials of Trade (MOTs).

The answer is yes. One definition of MOTs is hazardous materials transported by a private carrier in direct support of a business that is other than transportation by highway. Provided all conditions of § 173.6 are met, the materials of trade exception may be applied.

I hope this information is helpful.



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

Regulation Sections

Section Subject
173.6 Materials of trade exceptions