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Interpretation Response #99-0238 ([Specialty Gases of America, Inc.] [Mr. Jason C. Pollman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Specialty Gases of America, Inc.

Individual Name: Mr. Jason C. Pollman

Location State: OH Country: US

View the Interpretation Document

Response text:

January 28, 2000


Mr. Jason C. Pollman                   Ref. No. 99-0238
Specialty Gases of America, Inc.
5242 Tractor Rd. Unit H
Toledo, OH 43612

Dear Mr. Pollman:

This is in response to your letter and subsequent telephone conversation with Michael Johnsen of my staff concerning the materials of trade (MOTs) exception in § 173.6 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask whether Division 2.1 and 2.2 materials transported by your customers as private carriers either from your distribution center to their facility or between your customers various locations may be transported under the materials of trade exception.

Since your customers (e.g., welders or florists) transport hazardous materials in support of their business and their primary business is not transportation by motor vehicle, the hazardous materials can be transported under the MOTs exception provided all the provisions in § 173.6 are met, If your customers hire a contractor or other transportation company to transport these hazardous materials, the MOTs exceptions do not apply.

You also had a question concerning the registration and shipping paper requirements for shipments on your company's vehicles of Division 2.1 and 2.2 materials with an aggregate gross weight of less than 1000 pounds.  Companies which ship specific materials and amounts outlined in § 107.601 must register.  If your company is required to register, then § 107.620(b) requires that a copy of the registration, or another document with the registration number (identified as the “U.S. DOT Hazmat registration No.”) be carried on board each truck.  Shipping papers must accompany all hazardous materials shipments unless explicitly excepted from shipping paper requirements in the regulations.  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