Guidanceguidance
99-0190
North Central Laboratories — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research99-0190
Page 1of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Special Programs Administration AUG 4 1999 Ms. Pat Albrecht Ref. No. 99-0190 North Central Laboratories P.O. Box 8 Birnamwood, WI 54414 Dear Ms. Albrecht: This is in response to your letter dated July 14, 1999, requesting clarification of the definition for materials of trade under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically you ask if hazardous materials transported between your company's facilities may be considered materials of trade. One criteria for a material of trade is that a hazardous material is transported by a private carrier in direct support of its principal business which may not be transportation by motor vehicle. If the hazardous materials transported between your company's facilities are used to, support the business, and provided all condition of § 173.6 are met, the materials of trade exception may be applied to your scenario. I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 990190 118 SEA...#
Page 2FROM : NO OF WISCONSIN INC. PHONE NO.: 17154492454 Jul. 14 1992 NCL north central laboratories PO. Box 8 Birnamwood. Wl 54414 715-449-2673 TAX TRANSMISSION 8173.6 99-0190 DATE: 07/14/99 To: Mr. Edward I. Mazzullo From: Pat Albrecht Director, Office of Hazardous North Central Labs Material Standards FAX#: 1-715-449-2454 FAX#: 202-366-3012 Phone: 1-715-449-2693 Dear Mr. Mazzullo, I need to obtain a letter from your office in regards to an email question that was answered via a call back by your office. My question was pertaining to transporting Hazardous materials, class 3, 8, 5.1 and 6.1 in 20L or 2.5kg or less amounts packing group Il and III from our manufacturing lab to our shipping building located about 1/8 mile away via public roads. I was told by your office that we could transport our products between our two buildings under CFR 173.6: 'Materials of Trade Exceptions". Could you please fax written confirmation of this so we may have it on file? Thank you, Pat allows Pat Albrecht NCL of Wisconsin, Inc.#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.