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Interpretation Response #99-0055 ([Suburban Propane] [Ms. Barbara J. Verdon])

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

Interpretation Response Details

Response Publish Date:

Company Name: Suburban Propane

Individual Name: Ms. Barbara J. Verdon

Location State: NJ Country: US

View the Interpretation Document

Response text:

APR 28, 1999


Ms. Barbara J. Verdon                           Ref No: 99-0055
Manager - Legal Administration
Suburban Propane
P.O. Box 206
Whippany, NJ 07982-0206

Dear Ms. Verdon:

This is in response to your letter of February 12, 1999, to the Office of Motor Carrier Research and Standards regarding the materials of trade exception in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your letter was referred to the Research and Special Programs Administration for response.

You provide a scenario where Suburban Propane, in the course of delivering propane to customers, transports small amounts of methanol for use as an additive to prevent internal freezing of regulators, valves and/or lines in your customers' propane systems.  You ask whether the methanol may be transported as a material of trade under the provisions of § 173.6.

The answer is yes.  The materials of trade definition in § 171.8 includes a private motor carrier transporting hazardous materials in direct support of a principal business that is other than transportation by motor vehicle.  Your primary business is supplying propane to customers; in the course of that business you use small amounts of methanol to directly support the business.  However, if you delivered the methanol to your customers for their eventual use it would not be considered a material of trade.

Please be aware that all the provisions of § 173.6 must be met.  Packaging for materials of trade must be the manufacturer's original packaging or a packaging of equal or greater strength and integrity.  In addition, all packagings for liquids must be leaktight and securely closed.

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