There will inevitably be a time when you are asked about how to transport a small quantity of a hazardous material to another location without going through the process of hiring a licensed hazardous material transporter. Some situations like the transport of samples to a collaborating facility may fall under the Materials of Trade classification. I am by not stretch of the imagination encouraging the transport of hazardous materials in any other way than in full compliance with all regulations, so please do not read this as a suggestion to do so! However, certain hazardous materials may be transported in small quantities by vehicle as a Material of Trade (MOT) regulated under 49 CFR 173.6.
Materials of Trade (MOT) are defined as hazardous materials, other than hazardous waste, that are carried on a motor vehicle:
- to protect the health and safety of the motor vehicle operator or passengers, such as insect repellant or a fire extinguisher;
- to support the operation or maintenance of a motor vehicle (including its auxiliary equipment), such as a spare battery or gasoline; or
- to directly support a principal business of a private motor carrier (including vehicles operated by a rail carrier) that is other than transportation by motor vehicle – for example, landscaping, pest control, painting, plumbing, or welding services
Remember it is your responsibility to know what is being transported and how the Hazardous Materials Regulations (HMR) apply to your situation.