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How to Carry Hazmat With DOT's Materials of Trade Exception

Posted on 7/19/2021 by Roseanne Bottone

As part of normal business operations, employees of your company may need to transport relatively small amounts of hazardous materials in company (or other private) vehicles. The DOT offers some relief from full hazmat rules for these situations with their “Material of Trade” (MOT) exception at 49 CFR 173.6.

First, let’s look at how a material of trade is defined [See 49 CFR 171.8 definitions]. A MOT is transported in a motor vehicle for the sole purpose of:
  • Protecting the health and safety of the operator or passengers; 
  • Supporting the operation or maintenance of the motor vehicle; or
  • Directly supporting a principal business (that is not transportation).
A fire extinguisher on board a motor vehicle, a spare can of gasoline, and a chemical sample going to a lab are examples of each of the above, respectively.

These hazardous materials would be excluded from most standard packaging, marking, labeling, and shipping paper requirements, provided they meet certain conditions.

Which Hazard Classes Can be Carried as a Materials of Trade?

Any hazard class may be carried as a material of trade EXCEPT the following:
  • Class 1 explosives
  • Division 2.3 poisonous gases
  • Division 4.1 self-reactive solids
  • Division 4.2 spontaneously combustible materials
  • Division 4.3 dangerous when wet materials in Packing Group I
  • Division 6.1 poisonous by inhalation materials
  • Division 6.2, Category A infectious substances
  • Class 7 radioactive materials
 
In addition, you may not transport hazardous wastes (i.e., RCRA hazardous wastes requiring the use of a Uniform Hazardous Waste Manifest for offsite shipment) as a MOT.

Packaging Hazmat Materials of Trade

Packagings must be leak tight or sift proof and securely closed. The manufacturer’s original packaging or packagings of equal or greater strength must be used. Outer packagings are not required.

There are unique or additional requirements for two specific types of hazardous materials:

Gasoline must be packaged in DOT- or OSHA-approved metal or plastic packagings. DOT- or OSHA-approved metal or plastic packagings must be used to transport gasoline.

Cylinders containing Division 2.1 flammable gases or 2.2 non-flammable, non-poisonous compressed gases must conform to the hazardous materials regulations (except that outer packagings are not required.)

Materials of Trade Quantity Limits

DOT limits how much hazardous material may be carried under the Materials of Trade exception.
The gross aggregate weight of all MOT on a motor vehicle generally may not exceed 200 kg (i.e., 440 lbs.). There are also quantity limits per package that are based on hazard class and packing group.

Hazmat Labels and Placards

MOT packages are not required to be labeled, except for cylinders. The shipment also does not require placarding.

Shipping papers and emergency response information do not have to accompany the shipment.

Proper Loading and Info Sharing

You can’t just toss MOT packages in the back of a pickup and be on your way. The packages must be secured against shifting and protected against damage.

The driver must be informed about the presence of the hazardous material on the vehicle as well as the requirements of the MOT exception.

Real World Application: Welding

acetylene cylinders materials of tradeQuestion: We have to do some welding at several company offsite facilities. How do we transport our acetylene cylinders?

Answer: Acetylene is a division 2.1 flammable gas and is regulated as a hazardous material. However, since you will use it to conduct business, you may transport it as a Material of Trade (MOT) if you meet the conditions stated above.

While most MOTs do not require hazard labels, cylinders do. The cylinder must display the flammable liquid label.  

The maximum gross aggregate weight of a MOT cylinder is 100 kg (i.e., 220 lbs.). Since the maximum gross aggregate weight per vehicle for MOTs is 440 lbs., if your cylinders are 220 lbs., you could carry two of them.

Hazmat Training: Materials of Trade Online Course 

The Transporting Materials of Trade Online Course provides training for employees who routinely carry hazardous materials with them in a motor vehicle for business use.

Workers must be trained to understand the hazards of the materials they carry and the 49 CFR requirements that apply to materials of trade or MOTs. See 49 CFR 173.6(c)(4). 

Hazmat Training: 49 CFR Compliance for Shippers

For manager at facilities that ship hazardous materials in bulk or non-bulk quantities, including limited quantities, Lion offers DOT hazmat shipper training to help satisfy US DOT training requirements.

The Hazmat Ground Shipper Certification Online Course guides new shippers through a 10 Step(c) process to classify, name, package, mark, label, and document hazmat ground shipments in full compliance with the 49 CFR Hazardous Materials Regulations (HMR). 

IATA DGR and IMDG Code training are available for air and vessel shippers, and cover the latest international requirements for 2021. 

For experienced shippers, a recurrent DOT hazmat course is also available.

Tags: DOT compliance, hazmat transportation, materials of trade, MOT

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