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Materials of Trade (MOTS)

Certain hazardous materials transported in small quantities as part of a business are subject to less regulation, because of the limited hazard they pose. These materials are known as Materials of Trade.

Materials of Trade (MOTs) means a hazardous material, other than a hazardous waste, that is carried on a motor vehicle—

(1) For the purpose of protecting the health and safety of the motor vehicle operator or passengers; (i.e. fire extinguisher, insect repellant)

(2) For the purpose of supporting the operation or maintenance of a motor vehicle (including its auxiliary equipment such as a spare battery or extra gasoline); or

(3) By a private motor carrier in direct support of a principal business that is other than transportation by motor vehicle. hazardous materials, other than hazardous waste, that are carried on a motor vehicle. (i.e. oxygen and acetylene cylinders for a welder, gasoline for a landscaper or construction equipment)

The regulations that apply to MOTs are found in 49 CFR Section 173.6.

The driver must have a general knowledge of the MOT regulations to include quantity limitations, packaging and labeling requirements.

When the material transported meets the requirement many other general hazardous material regulations are no longer required such as shipping papers, emergency response information, and placarding since quantities are low and for lower hazard items as a result. In addition, relief exists from the formal training and record requirements of same.

Limits do apply in order to qualify as a MOT and they are as follows;

No more than a combined gross weight of (440lbs) of Materials of Trade can be transported on any one vehicle. (exception for tanks containing diluted mixtures of Class 9 materials)

Individual packages size limits;

  • If a hazardous material is a high-hazard material (Packing Group I), the maximum amount of material in one package is 1lb for solids, or 1pt for liquids.
  • If the hazardous material is a medium or lower hazard – that is, if it belongs to Packing Group II or III, other than division 4.3, or is a consumer commodity (ORM-D) the maximum amount of material in each package is 66lbs for solids, or 8 gal. for liquids.
  • For Division 4.3 materials (only Packing Group II and III materials are allowed) the maximum amount of material in each package is 1oz.
  • Each cylinder containing a gas (Division 2.1 or 2.2) may not weigh more than 220 lbs.
  • A diluted mixture of a Class 9 material (not exceeding 2% concentration) may be transported in a tank having a capacity of up to 400 gallons.

 

What are the Packaging and Marking Requirements for MOTs?

The packaging must be the manufacturer’s original packaging or of similar strength and integrity. The packaging must be marked with a common name (such as “gas” or “spray paint”) or a proper shipping name from the HMR (such as “Isopropyl Alcohol”.)

Additionally, the following other requirements apply to MOTs:

  • Packagings must not leak.
  • Packages must be securely closed, secured, and protected against damage.
  • Outer packagings are not required for receptacles (such as cans or bottles) if they are secured against movement.
  • Gasoline must be transported in a metal or plastic container meeting DOT or OSHA requirements (Section 173.6 (b) (4) and Section 173.202 in the HMR).
  • The actual Cylinders and pressure vessels must conform to the HMR except that outer packagings are not required. These cylinders must be marked with the proper shipping name and identification number and have a hazard class warning label.
  • If the package contains a reportable quantity of a hazardous substance, it must be marked “RQ”. Reportable quantities are found in Appendix A of Section 172.101 in the HMR.
  • A tank containing a diluted mixture (not more than 2% concentration) of a Class 9 material must be marked on two opposing sides with the identification number.

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