Materials of Trade
Sometimes in the course of our work we have to carry in our vehicles certain things like caulking, paint, solvents, etc. that are considered by the DOT to be hazardous materials.
A hazardous material is “a substance or material which has been determined by the U.S. Department of Transportation (DOT) to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce.”
Materials of Trade (MOTs) are hazardous materials (other than hazardous waste), that are carried on a motor vehicle and used in the course of a person’s daily work. MOTs might include gases for a welder, paint for a painter, fuel for a landscaper, or caulk for a carpenter. As such, the quantity of materials will be limited, but the driver will not need to have a hazmat endorsement (and a CDL license) or need to have hazmat placards on the vehicle, shipping papers, emergency response information
Note that MOTs are carried on a motor vehicle. Placement of the materials in the vehicle
One client was stopped at a roadside inspection and ticketed for having a box of caulking on the front seat of his pickup.
Top Tip: Keep MOTs out of the cab of the vehicle.
And don’t just toss a cylinder in the back of a truck or have the MOTs piled loosely on a flatbed or in a cargo vehicle as a van or enclosed trailer.
Top Tip: Properly secure any and all MOTs you carry or haul.
Knowledge about MOT is important.
The regulations that apply to MOTs are found in 49 CFR Section 173.6. They include:
• general knowledge of MOTs regulations;
• quantity limitations;
• packaging requirements; and
• marking and labeling requirements.
Know the MOT quantity limits . . .
With the exception of tanks containing diluted mixtures of Class 9 materials, no more than a combined gross weight of 200 kg (440 lbs) of Materials of Trade can be transported on any one vehicle. Size limits for individual packages apply to Materials of Trade as described below: • If a hazardous material is a high-hazard material (Packing Group I), the maximum amount of material in one package is 0.5 kg (one lb) for solids, or 0.5 L (one pt) 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 30 kg (66 lbs) for solids, or 30 L (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 30 ml (one oz.)
• Each cylinder containing a gas (Division 2.1 or 2.2) may not weigh more than 100 kg (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 1500 L (400 gal.)
Hauling MOT quantities beyond these limits means the organization and driver need to meet the regulatory requirements of hauling hazardous materials.
And you don’t really want to go there if you don’t have to . . .
Thank you for reading this.