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Interpretation Response #99-0074 ([HMT Associates] [Mr. E.A. Altemos])

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

Interpretation Response Details

Response Publish Date:

Company Name: HMT Associates

Individual Name: Mr. E.A. Altemos

Location State: DC Country: US

View the Interpretation Document

Response text:

APR 8, 1999


Mr. E.A. Altemos                             Ref.  No. 99-0074
HMT Associates
Suite 200
1850 K Street
Washington, D.C. 20006-3500

Dear Mr. Altemos:

This is in response to your letter dated March 18, 1999, requesting clarification of § 173.6 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether a prior interpretation concerning the materials of trade exceptions would remain valid under the following alterations of the scenario outlined by that prior interpretation.

1)   Rather than transport being conducted between two buildings separated by a road with public access, the transport was conducted on public highways between facilities that may be separated by many miles;

2)   Rather than being Carried in a company-owned vehicle, the hazardous materials concerned are carried in the privately-owned vehicle of a company employee; and/or

3)   Rather than the operation described being ‘not a normal business practice', the operation is a routine business practice.

Provided that all the requirements of § 173.6 are met, transport can be conducted on public highways of any distance, can be carried in privately-owned or company vehicles, and such shipments  can routinely take place.

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