{"operation":"document","citation":"98-0503","title":"United Surveyors of Chemicals, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-02-23","effective_on":null,"summary":"98-0503 response to United Surveyors of Chemicals, Inc. concerning 173.6.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0503.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0503.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0503","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980503.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S.Department\nWashington, D.C.\n400 Seventh Street, S.W\n20590\nResearch and\nSpecial Programs\nAdministration\nFEB 23 1998\nMr. Jeffrey M. Moses, CMTS\nDirector of Services\nUnited Surveyors of Chemicals, Inc.\nP.O. Box 3555\nBaytown, Texas 77522-3555\nDear Mr. Moses:\nThis is in response to your letter of January 13, 1998, regarding transportation of small\nquantities of chemicals transported by your business under the Hazardous Materials\nRegulations (HMR; 49 CFR parts 171-180). You state that your company is a licensed public\ngauger and accredited laboratory which serves the chemical industry. Your primary business\nis analyzing products for customers using small amount of hazardous materials in the process.\nAdditionally, you may transport small amounts of hazardous materials that you use to wash\nthe walls of ships and analyze the run off to determine amounts of contamination. You ask\nwhether the hazardous materials you use to perform these analyses may be considered\nMaterials of Trade (MOTs).\nThe answer is yes. One definition of MOTs is hazardous materials transported by a private\ncarrier in direct support of a business that is other than transportation by highway. Provided\nall conditions of § 173.6 are met, the materials of trade exception may be applied.\nI hope this information is helpful.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\npolydous\nTile: 173.6\nSC: 142,124\nUnited Survzyors of Chemicals, Inc.\nPO BOX 3555 BAYTOWN, TEXAS 77522-3555 PHONE 1-800-872-2436\n1128\nleft message\nJanuary 13, 1998\nEdward Mazzullo, Director\ncalled\nOffice of Hazardous Materials Standards\n400 7\" Street SW\nWashington, DC 20590\n-\nDear Sir:\nI would appreciate your opinion as to whether the \"Materials of Trade (MOT)\" exception\nin 49 CFR$173.6 would apply, as follows:\nMy company is a licensed public gauger and accredited laboratory serving\nthe chemical industry.\nWhile acting as a private carrier, we transport liter-size bottles of chemicals\n(classes 3, 8, and 9; and division 6.1) to our laboratory, or to other\nlaboratories, for our clients.\n3.\nWe also transport liter-size bottles of chemicals utilized for wall-washing ships\nand barges to and from the job site.\n. All origins and destinations regarding the chemicals are within the State of\nTexas.\n4. The clients for whom we transport the chemicals are manufacturers and\ndistributors or trading companies. We do not transport chemicals for any\ncompany whose principal business is transportation by motor vehicle.\nThanks, in advance for your help in this matter.\nSincerely.\nI uses MOT for analysis\ncustomer product\nher mat\nDirector of Services\nprimary\nanalysing","truncated":false,"body_characters":2711}