1
PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
UNDERSTANDING
MATERIALS OF TRADE (MOTs)
Ullore niti torere moluptassum quiae ©
WWW.PHMSA.DOT.GOV
The contents of this guide do not have the force and eect of law and are not meant to bind the public in any way. This guide is
intended only to provide information to the public regarding existing requirements under the Hazardous Materials Regulations.
3
UNDERSTANDING MATERIALS OF TRADE MOT
Are You Transporting Hazmat? . . . . . . . . . . . . . . . . . . . . . . . . . . .04
Safety Data Sheet (SDS) Example . . . . . . . . . . . . . . . . . . . . . . . . .05
Materials of Trade (MOTs) Defined . . . . . . . . . . . . . . . . . . . . . . . . .06
Why Do MOTs Matter to You? . . . . . . . . . . . . . . . . . . . . . . . . . . . 07
Limitations and Requirements for MOTs:
Qualifying Hazardous Materials . . . . . . . . . . . . . . . . . . . . . . . . . .08
Quantity Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .09
Packaging and Marking Requirements . . . . . . . . . . . . . . . . . . . . . . .10
Questions About MOTs? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
TABLE OF CONTENTS
4
Whether you are self-employed or work for a large
company, it is your responsibility to know if you are dealing
with hazmat. One possible starting point for determining
whether a product you transport is hazmat is to consult the
product’s S D S (SDS), provided by the
manufacturer. This should include a transportation hazard
classification for the product, with a four-digit ID number, a
proper shipping name, the hazard class, and the packing
group for the product (in Section 14: Transportation
Information, per the example on page 5).
You are responsible for transporting hazmat in accordance with the Hazardous Materials Regulations
(HMR; 49 CFR Parts 171 – 180), including properly classifying and packaging the materials with all required hazard
communication. These requirements may be dependent upon the quantity and hazard of the specific material (see the
H M T (HMT) § 172.101).
Ullore niti torere moluptassum quiae ©
Do you carry  as part of your job?
Liquid fuels, paint thinners, pesticides, and even lithium
cells and batteries are all classified as hazardous materials
(hazmat), because they can pose an unreasonable risk
to health, safety, and property when transported
in commerce (§ 171.8)
ARE YOU TRANSPORTING HAZARDOUS MATERIALS?
Department of Transportation
hazmat regulations only apply to
the transportation of hazardous
materials IN COMMERCE.
In other words, they do not apply
if you are transporting hazmat for
non-commercial purposes in a
private motor vehicle.
5
PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
SAFETY DATA SHEET EXAMPLE
SECTION 14
Section 1: Identification
Product Name: Spirit Lacquer Thinner
Product Code: 02252022
Other means of Identification: N/A
Product type: Liquid
Relevant identified uses of the substance or mixture and uses advised against: Paint, stain, and
varnish thinning
Manufacturer: Wandering Artist’s Paint
6 Golden Tree Ln
Limgrave, CA 94129
(415) 835-1174
Emergency contact information: Calling Bell 24 Hour Emergency Services
US/Canada: (800) 310-4000
International: +1 415 310 4000
Section 2: Hazard Identification
OSHA/HCS status: This material is considered hazardous by the OSHA Hazard Communication
Standard (29 CFR 1910.1200).
Hazard Classification:
FLAMMABLE LIQUIDS - Category 2
ACUTE TOXICITY (oral) - Category 4
SKIN CORROSION/IRRITATION - Category 2
SERIOUS EYE DAMAGE/ EYE IRRITATION - Category 1
CARCINOGENICITY - Category 2
TOXIC TO REPRODUCTION - Category 2
SPECIFIC TARGET ORGAN TOXICITY (SINGLE EXPOSURE) (Respiratory tract irritation) -
Category 3
SPECIFIC TARGET ORGAN TOXICITY (SINGLE EXPOSURE) (Narcotic effects) - Category 3
SPECIFIC TARGET ORGAN TOXICITY (REPEATED EXPOSURE) - Category 2
ASPIRATION HAZARD - Category 1
Percentage of the mixture consisting of ingredient(s) of unknown acute toxicity: 32.2%
(oral), 51% (dermal), 51% (inhalation
Signal Word: Danger
Hazard Statements:
Highly flammable liquid and vapor.
Harmful if swallowed.
May be fatal if swallowed and enters airways.
Causes skin irritation.
Causes serious eye damage.
May cause respiratory irritation.
May cause drowsiness or dizziness.
Suspected of causing cancer.
Suspected of damaging fertility or the unborn child.
U.S. DOT Classification: UN1263, Paint related materials, 3, II
UN Number: UN1263
Proper Shipping Name: Paint related materials
Hazard Class: Class 3 (flammable liquids)
Packing Group: II
Hazardous Substance: No
Marine Pollutant: No
TDG, ICAO and IMDG: UN1263, Paint related materials, 3, II
May cause damage to organs through prolonged or repeated exposure.
Precautionary Statements: Obtain special instructions before use. Do not handle until all safety
precautions have been read and understood. Wear protective gloves, protective clothing and eye or
face protection. Keep away from heat, hot surfaces, sparks, open flames and other ignition sources.
No smoking. Use explosion-proof electrical, ventilating or lighting equipment. Use non-sparking tools.
Take action to prevent static discharges. Use only outdoors or in a well-ventilated area. Do not
breathe vapor. Do not eat, drink or smoke when using this product. Wash thoroughly after handling.
Description hazards not otherwise known: N/A
Section 14: Transport Information
Section 1: Identification
Product Name: Spirit Lacquer Thinner
Product Code: 02252022
Other means of Identification: N/A
Product type: Liquid
Relevant identified uses of the substance or mixture and uses advised against: Paint, stain, and
varnish thinning
Manufacturer: Wandering Artist’s Paint
6 Golden Tree Ln
Limgrave, CA 94129
(415) 835-1174
Emergency contact information: Calling Bell 24 Hour Emergency Services
US/Canada: (800) 310-4000
International: +1 415 310 4000
Section 2: Hazard Identification
OSHA/HCS status: This material is considered hazardous by the OSHA Hazard Communication
Standard (29 CFR 1910.1200).
Hazard Classification:
FLAMMABLE LIQUIDS - Category 2
ACUTE TOXICITY (oral) - Category 4
SKIN CORROSION/IRRITATION - Category 2
SERIOUS EYE DAMAGE/ EYE IRRITATION - Category 1
CARCINOGENICITY - Category 2
TOXIC TO REPRODUCTION - Category 2
SPECIFIC TARGET ORGAN TOXICITY (SINGLE EXPOSURE) (Respiratory tract irritation) -
Category 3
SPECIFIC TARGET ORGAN TOXICITY (SINGLE EXPOSURE) (Narcotic effects) - Category 3
SPECIFIC TARGET ORGAN TOXICITY (REPEATED EXPOSURE) - Category 2
ASPIRATION HAZARD - Category 1
Percentage of the mixture consisting of ingredient(s) of unknown acute toxicity: 32.2%
(oral), 51% (dermal), 51% (inhalation
Signal Word: Danger
Hazard Statements:
Highly flammable liquid and vapor.
Harmful if swallowed.
May be fatal if swallowed and enters airways.
Causes skin irritation.
Causes serious eye damage.
May cause respiratory irritation.
May cause drowsiness or dizziness.
Suspected of causing cancer.
Suspected of damaging fertility or the unborn child.
U.S. DOT Classification: UN1263, Paint related materials, 3, II
UN Number: UN1263
Proper Shipping Name: Paint related materials
Hazard Class: Class 3 (flammable liquids)
Packing Group: II
Hazardous Substance: No
Marine Pollutant: No
TDG, ICAO and IMDG: UN1263, Paint related materials, 3, II
May cause damage to organs through prolonged or repeated exposure.
Precautionary Statements: Obtain special instructions before use. Do not handle until all safety
precautions have been read and understood. Wear protective gloves, protective clothing and eye or
face protection. Keep away from heat, hot surfaces, sparks, open flames and other ignition sources.
No smoking. Use explosion-proof electrical, ventilating or lighting equipment. Use non-sparking tools.
Take action to prevent static discharges. Use only outdoors or in a well-ventilated area. Do not
breathe vapor. Do not eat, drink or smoke when using this product. Wash thoroughly after handling.
Description hazards not otherwise known: N/A
Section 14: Transport Information
6
MATERIALS
OF TRADE
or MOTs, are a certain
category of hazmat
which, when transported
in small quantities as
part of a business, are
subject to fewer HMR
requirements due to the
limited hazard they pose.
6
7
PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
WHY DO MOTs MATTER TO YOU?
MOTs are hazmat, other than a hazardous waste, that are carried on a MOTOR VEHICLE in certain quantities 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 (including its auxiliary equipment), such as a
spare battery or gasoline; or
•
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, chemicals for landscaping,
pest control, painting, or plumbing services, or gases for welding.
There is an exception for MOTs that provides less stringent regulatory
requirements. When transported in accordance with § 173.6 of the HMR,
the following requirements are NOT applicable to MOTs:
•
Shipping papers
•
Emergency response information
•
Placarding
•
Formal training or retention of training records.
The following HMR limitations and requirements DO apply to MOTs*:
•
Material limitations;
•
Quantity limitations;
•
Packaging, marking, and labeling requirements; and
•
General knowledge of MOTs (found in § 171.8).
*See § 173.6 “Materials of trade exceptions.”
The MOTs exception does not
apply to transport of these
hazardous materials by other
modes of transport, including by
aircraft or vessel.
In addition, the exception does
not apply to these materials
when in motor vehicles
  .
7
8
LIMITATIONS AND REQUIREMENTS FOR MOTs
QUALIFYING HAZARDOUS MATERIALS
MOTs are limited to the following hazard classes or divisions:
CLASS OR DIVISON DESCRIPTION EXAMPLES
Division 2.1
Flammable Gases
acetylene, propane
Division 2.2
Non-flammable Gases
oxygen, nitrogen
Class 3
Flammable or Combustible Liquids
paint, paint thinner, gasoline
Division 4.1
Flammable Solids
charcoal
Division 4.3
Dangerous When Wet Materials
fumigants, metal powders (e.g., magnesium, zinc)
Division 5.1
Oxidizers
bleaching compounds
Division 5.2
Organic Peroxides
benzoyl peroxide
Division 6.1
Poisons
pesticides
Division 6.2
Infectious Substances**
diagnostic specimens
Class 8
Corrosive Materials
muriatic acid, drain cleaners, battery acid
Class 9
Miscellaneous Hazardous Materials
lithium batteries, asbestos, self-inflating lifeboats
** Only Div. 6.2 materials, other than a Category A infectious substance, contained in human or animal samples being transported for
research, diagnosis, investigational activities, or disease treatment or prevention, or that is a biological product or regulated
medical waste (§ 173.6(a)(4))
Materials and products that are classified into any other hazard class or division
(e.g., Class 1 Explosives, Division 2.3 Poison by Inhalation Gases) are NOT ELIGIBLE
to be transported under the MOTs exception.
9
PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
***Not including diluted mixtures (not exceeding 2 percent concentration) of Class 9 materials
QUANTITY LIMITS
Use the flow chart below to determine the quantity
limitations per package of a given MOT, based on Packing
Group (PG) and hazard class/division. You can find the PG
and hazard class/division listed in Section 14 of the SDS,
columns 5 and 3 (respectively) of the Hazardous Materials
Table, or as part of the Basic Description on previous
shipping paper(s). Note that the aggregate gross weight
of all MOTs—that is, the total weight of all hazardous
materials and its packaging loaded on a single vehicle—
may not exceed 200 kg (440 lbs.). ***
BE CAREFUL!
MOTs have strict quantity limitations.
If you exceed these limits, the material
will be fully regulated under the HMR.
PG II, PG III
or no PG
Div. 2.1, 2.2
Class 3, 8
Div 4.1, 5.1, 5.2, 6.1
Div. 6.2
Div. 4.3
Class 9
What is the hazard
class or division?
Is it a liquid
in a diluted
mixture not
exceeding 20%
concentration?
Maximum amount of material in
one package is 0.5 kg (1 lb.) for
solids, or 0.5 L (1 pint) for liquids
Maximum
gross capacity
of each
package is
30 mL (1 oz.)
See specific
packaging and
quantity limits
listed in
§ 173.6(a)(4)
May be transported
in a tank having a
capacity of up to
1500 L (400 gal)
Maximum amount of
material in each package
is 30 kg (66 lbs.) for solids,
including lithium batteries
contained in equipment,
or 30 L (8 gal) for liquids
Each cylinder
may not
weigh more
than 100 kg
(220 lbs.) gross
Start with the Packing Group (PG):
PG I
NO YES
10
PACKAGING AND MARKING REQUIREMENTS
MOT MUST BE PACKAGED AND MARKED AS FOLLOWS:
Packaging
•
The packaging must be the manufacturer’s original
packaging or of equal or greater strength
and integrity.
•
Packagings must be leak tight for liquids and gases
and sift proof for solids.
•
Packages must be properly closed, secured against
movement, and protected against damage.
•
Outer packagings are not required for receptacles
(such as cans or bottles) that are secured against
movement in cages, bins, boxes, or compartments.
•
Gasoline must be transported in a metal or plastic
container meeting HMR or OSHA requirements
(see §§ 173.6(b)(4) and 173.202 in the HMR).
•
Cylinders and pressure vessels must conform to
HMR requirements, except that outer packagings
are not required.
Marking
•
The packaging must be marked with either a
common name (such as “gas” or “spray paint”)
or a proper shipping name from the HMR
(such as “isopropyl alcohol”).
•
A tank containing a diluted mixture (not more
than 2% concentration) of a Class 9 material
must be marked with the identification number
on two opposing sides.
•
Cylinders and pressure vessels must be marked
with the proper shipping name and identification
number and have a hazard class warning label.
•
If the package contains a reportable quantity
of a hazardous substance, it must be marked
“RQ” (reportable quantities are found in
Appendix A of Section 172.101 in the HMR).
MATERIAL REQUIREMENT
Liquids
•
Inner packaging must be leakproof
•
Outer packaging must contain sucient absorbent material to absorb
the entire contents of the inner packaging.
Sharps
•
Inner packaging (sharps container) must be constructed of a rigid material
resistant to punctures and securely closed to prevent leaks or punctures.
•
Outer packaging must be securely closed to prevent leaks or punctures.
Solids, Liquids, Sharps
•
Outer packaging must be a strong, tight packaging securely closed and
secured against shifting, including relative motion between packages,
within the vehicle on which it is being transported.
Division 6.2 infectious substances must be contained in a combination packaging which meets the
following requirements:
11
PHMSA | PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
QUESTIONS ABOUT MOTs?
While MOTs exceptions oer relief from certain HMR requirements, remember that these materials are still hazmat.
To operate under MOTs, you must adhere to all the requirements listed in § 173.6—including all quantity restrictions.
Concerned that your operational needs might exceed MOTs quantity limitations? Contact the Hazardous Materials Info
Center at (1-800-467-4922) or via email at @. for answers to your questions. PHMSA also provides
compliance assistance resource on our  , including guides to hazmat law, registration, hazmat training
programs, transportation requirements, and more.
Pipeline and Hazardous Materials
Safety Administration
Outreach, Training, and Grants Division
East Building, 2nd Floor
1200 New Jersey Ave., SE
Washington, DC 20590
Email: training@dot.gov
202-366-4900
202-366-7342 (Fax)
For additional information contact:
The Hazardous Materials Info Center
1-800-HMR-4922
(1-800-467-4922)
Email: [email protected]
PHH50-0202-0523
www.phmsa.dot.gov