dgardner
Moderator
I dashed off an email yesterday to the PHMSA (Pipeline and Hazardous Materials Safety Administration - part of DOT) and asked for some clarification. I expected a vague reply in a few weeks. Imagine my surprise when a nice lady called me today! She did indicate that the regs that specifically call for within arms reach (and most of 49CFR) applies to carriers that are shipping hazardous materials, not us. The primary driver for us is OSHA.
She did point out (this I did not know) that our situation does fall under something called "Materials of Trade". From a pamphlet she directed me to:
Materials of Trade (MOTs) are hazardous materials, other than hazardous waste, that are carried on a motor vehicle:
• 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.
The two-page pamphlet explains more:
http://phmsa.dot.gov/pv_obj_cache/p...1158E8CCC9BAD7ECA407F1100/filename/mots05.pdf
From the pamphlet:
Certain hazardous materials transported in small quantities as part of a business are subject to less regulation, because of
the limited hazard they pose. These materials are known as Materials of Trade
More:
The MOTs regulations do not require:
• shipping papers;
• emergency response information;
• placarding; or
• formal training or retention of training records.
She did point out (this I did not know) that our situation does fall under something called "Materials of Trade". From a pamphlet she directed me to:
Materials of Trade (MOTs) are hazardous materials, other than hazardous waste, that are carried on a motor vehicle:
• 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.
The two-page pamphlet explains more:
http://phmsa.dot.gov/pv_obj_cache/p...1158E8CCC9BAD7ECA407F1100/filename/mots05.pdf
From the pamphlet:
Certain hazardous materials transported in small quantities as part of a business are subject to less regulation, because of
the limited hazard they pose. These materials are known as Materials of Trade
More:
The MOTs regulations do not require:
• shipping papers;
• emergency response information;
• placarding; or
• formal training or retention of training records.
