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Interpretation Response #99-0081 ([Eastman Chemical Company] [Ms. Julie Brown])

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

Interpretation Response Details

Response Publish Date:

Company Name: Eastman Chemical Company

Individual Name: Ms. Julie Brown

Location State: TN Country: US

View the Interpretation Document

Response text:

APR 28, 1999


Ms. Julie Brown                          Ref. No. 99-0081
Eastman Chemical Company
Logistics Compliance
P.O. Box 431
Kingsport, TN 37662-5280

Dear Ms. Brown:

This is in response to your letter of March 29, 1999, requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether Eastman Chemical Company's chemists transporting small amounts of hazardous materials to schools to conduct experiments for educational purposes would fall under the material of trade definition in § 171.8.

The answer is yes.  In order to take advantage of the material of trade exception, criteria in the definition for material of trade in § 171.8 must be met.  A material of trade is a hazardous material, other than a hazardous waste, that is carried on a motor vehicle for the purpose of: (1) protecting the health and safety of the motor vehicle operator or passengers; (2) for the purpose of supporting the operation or maintenance of motor vehicle; (3) by a private motor carrier in direct support of a principal business that is other than transportation by motor vehicle.  Eastman Chemical Company's chemists' primary responsibility is not transportation; therefore, the materials of trade exception would apply if all the requirements of § 173.6 are met.  These materials are not subject to any other requirements of the HMR other than those set forth in  §173.6.

I hope this information is helpful.  If we can be of further assistance, please contact us.



Hattie L. Mitchell, Chief
Regulatory Review And Reinvention
Office of Hazardous Materials  Standards


Regulation Sections

Section Subject
171.8 Definitions and abbreviations