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MODULE 9 Materials of Trade
Module 9 – Materials of Trade Introduction DOT has established Materials of Trade (MOT) exceptions that allow companies to transport small quantities of certain hazardous materials used in support of their primary business. These materials must meet specific guidelines to be classified as MOT. Materials classified as MOT are exempted from many regulations of the Hazardous Materials Regulations (HMR), such as shipping papers, emergency response information, or placarding, and do not require drivers to have any formal training in handling them. After completing this module, you will be able to explain: • What qualifies as MOT. • What hazard classifications can qualify for the MOT exception. • MOT quantity limitations and packaging requirements. • MOT marking and labeling requirements.
LESSON 1 What is a Material of Trade (MOT)?
Material of Trade Introduction DOT defines MOT as limited quantities of a hazardous material, other than a hazardous waste, that may be 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. • Support the operation or maintenance of a motor vehicle, such as a spare battery or gasoline. • Directly support the operations of the principal business, such as landscaping, pest control, painting, plumbing, or welding services. In the propane industry, a common example of MOT is a bobtail driver transporting a small container of methanol to assist in removing water from within a propane tank. Not all hazardous materials qualify for the MOT exception. Let’s review the requirements for both hazard classification and quantities permitted.
Classification Requirements To be transported as MOT, the hazardous material must belong to one of these specific classes or divisions: 2.1: Flammable Gases v such as acetylene and propane. 2.2: Non-flammable Gases v such as oxygen, nitrogen. 3: Flammable and Combustible Liquids –such as gasoline, paint, paint thinner. 4.1: Flammable Solids – such as charcoal. 4.3: Dangerous When Wet Materials – such as some fumigants. 5.1: Oxidizers – such as hydrogen peroxide. 5.2: Organic Peroxides – such as benzoyl peroxide.
Classification Requirements, cont. 6.1: Poisons – such as pesticides. 6.2: Some Infectious Substances – such as diagnostic specimens. 8: Corrosive Materials – such as muriatic acid, drain cleaners, and battery acid. 9: Miscellaneous Hazardous Materials – such as asbestos and self-inflating lifeboats. ORM-D: Consumer Commodities – such as hair spray and spray paints. You may not deal with all of these hazard classes as part of your day-to-day job, but you should know what they are in case you are asked to transport these MOT.
Quantity Limits The amount of hazardous material that can be transported under the MOT exception is limited. Drivers must know the capacity and weight of containers they are transporting to ensure they are in compliance with the quantity limits. This is especially important if more than one MOT is being transported. The total gross weight of all MOT carried on one motor vehicle cannot exceed 440 pounds. The following limits are based typically on hazard class divisions and packing groups: • If a material is a high-hazard material (PackingGroup I), the maximum amount in one package is one pound for solids, or one pint for liquids. • If the material is a medium- or lower-hazard material (Packing Group II or III) with the exception of Division 4.3 and Consumer Commodities (ORM-D), the maximum amount in each package is 66 pounds for solids, or 8 gallons for liquids.
Quantity Limits, cont. • For Division 4.3 materials (Packing Group II and III), the maximum amount in each package is one ounce. • Each cylinder containing a gas (Division 2.1 or 2.2) may not weigh more than 220 lb. • A diluted mixture of a Class 9 material may be transported in a tank having a capacity of up to 400 gallons.
Packaging Requirements According to DOT regulations, MOT must be packaged in the following ways: • Liquids and gases must be packaged in enclosed, leak-proof containers and secured to prevent movement or damage during transport. • Cylinders used to transport Division 2.1 (Flammable Gas) or 2.2 (Non-flammable Gas) MOT must conform to the packaging, qualification, maintenance, and use requirements of the HMR, except that outer packaging is not required. • Manifolding cylinders are authorized if valves are closed tightly. • Gasoline must be in metal or plastic packaging and conform to HMR and OSHA requirements.
Packaging Requirements, cont. • Materials must be packaged in their original packaging, or in a package of equal strength and quality. • Nonbulk packaging, other than cylinders, must be marked with the name of the material being carried. DOT-specification cylinders must be marked and labeled as required by the HMR. NOTE: Outer packaging is not required for cans and bottles secured in cages, carts, bins, boxes, or compartments to prevent movement. However, they cannot simply be placed in a can inside a bin. They must be secured to prevent movement.
Safely Transporting MOT As with all hazardous materials, MOT must be handled properly to minimize risk to yourself and others. Treat all of these materials with the same care and precaution you would if they were a placarded load. A driver or company who does not comply with these guidelines for transporting MOT may sustain fines ranging from $275 to as much as $100,000 per day as well as possibly face criminal penalties. In addition to HMR requirements, you should also follow any safety precautions present on the material’s commercial packaging. If you have any questions about how a particular hazardous material should be handled or transported, refer to its Safety Data Sheet (SDS).
LEARNING ACTIVITY Identify Materials of Trade