Materials of Trade exception is a species that lives only in the United States and only migrates by Ground. Materials of Trade is exactly what it sounds like. The whole idea is to provide relief to those trades who happen to use hazardous materials or dangerous goods while out on the road earning a buck.
Swimming pool maintenance vehicles carrying chlorine and acids, air conditioning companies carrying compressed gasses, home medical supply companies, mobile welding units, veterinarians, landscaping, pest control, painters, plumbers, get the idea?
Materials of Trade is not a giant loophole which allows manufacturers, distributors, and others to ship materials from one side of the city to the other for packaging, processing, or the like. In addition, there are strict requirements to qualify for this exception starting with the classes and divisions. If your materials don’t fall into one of these classes, game over.
- Flammable Gases (Division 2.1) acetylene, propane
- Non-flammable Gases (Division 2.2) oxygen, nitrogen
- Flammable or Combustible Liquids (Class 3) paint, paint thinner, gasoline
- Flammable Solids (Division 4.1) charcoal
- Dangerous When Wet Materials (Division 4.3) some fumigants
- Oxidizers (Division 5.1) bleaching compounds
- Organic Peroxides (Division 5.2) benzoyl peroxide
- Poisons (Division 6.1) pesticides
- Some Infectious Substances (Division 6.2) diagnostic specimens
- Corrosive Materials (Class 8) muriatic acid, drain cleaners, battery acid
- Miscellaneous Hazardous Materials (Class 9) asbestos, self-inflating lifeboats
- Consumer Commodities (ORM-D) hair spray, spray paints
If you are shipping one of the above materials, there are strict limitations to the quantities you may carry. The quantities are based on Packing Groups.
- Packing Group I 0.5 Liters / Kilos
- Packing Groups II or III 30 Liters / Kilos
There are other quantity limitations for specific classes and divisions. Also, the total combined quantity on the truck may not exceed 200 kilos or 440 pounds.
Okay, I meet all of the requirements above. Does this mean I don’t need training? On the contrary, you do need training and that training should consist of;
- General Awareness
- Packaging Requirements
- Marking & Labeling Requirements
- Quantity Limitations.
The Materials of Trade Exception does provide relief from formal training and retention of those training records, Shipping Paper requirements, Placarding, and Emergency Response information.
Please keep in mind, this is a general outline of the Materials of Trade Exception. There are other requirements and restrictions, Packagings, Gasoline, Hazardous Substances, and Cylinders to name a few. To find out more and see this animal up close, our friends at the DOT give us the DNA profile in 49CFR, Section 171.8 and the full genome sequencing in Section 173.6