4.2.3 Student Book © 2004 Propane Education & Research Council Page 1
4.2.3Transporting Materials of
Trade
To transport hazardous material as a material of trade, the material must meet the materials of trade definition, hazard classification, and quantity guidelines. Propane employees at times may be required to transport flammable paint, paint thinners, methanol, or wasp spray while on the job.
In this module you will learn to identify:
(1) Regulations pertaining to transporting materials of trade
(2) Safety requirements for transporting materials of trade
4.2.3 Student Book © 2004 Propane Education & Research Council Page 1
Regulations for Transporting Materials of Trade
DOT defines “Materials of Trade” as small amounts of certain hazardous materials transported on a motor vehicle for workers to use in direct support of their business.
When you transport small amounts of these materials under the Materials of Trade exceptions, you are not subject to some of the regulations that apply to the transportation of hazardous materials. These include:
• Shipping papers
• Placarding
• Emergency response information
• Training for hazardous materials carried as materials of trade
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Safety Requirements for Transporting Materials of Trade
Classification Requirements— The material must meet the materials of trade definition according to hazard classification and must belong to one of the following classifications:
Division 2.1 Flammable gas
Division 2.2 Non-flammable gas
Class 3 Flammable liquid
Division 4.1 Flammable solid
Division 4.3, PG II or III Dangerous when wet
Division 5.1 Oxidizer
Division 5.2 Organic peroxide
Division 6.1 Poison
Class 8 Corrosive
Class 9 Miscellaneous
ORM-D Other regulated material
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Safety Requirements for Transporting Materials of Trade
Quantity Requirements— Figure 1 conveys quantity limits that apply to Classes 3 and 8. The limits are gross mass or capacity and include the weight of the packaging.
Packing Group: Package Quantity Limits for Classes 3 and 8:
PG I Not over 1 pound or 1 pint
PG II or III Not over 66 pounds or 8 gallons
Figure 1. Quantity Limits
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Safety Requirements for Transporting Materials of Trade
Quantity Requirements
Figure 2. Excerpt from Hazardous Materials Table
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Safety Requirements for Transporting Materials of Trade
Packaging Requirements — The following guidelines must be met for you to use the materials of trade exceptions:
Liquids and Gases Leak proof, securely closed, secured to prevent movement, protected against damage
Gasoline Metal or plastic container and must conform to the HMR (Hazardous Material Regulations) or OSHA requirements
Materials must be packaged in the manufacturer’s original packaging or one of equal strength and quality.
Packaging for Hazardous Materials:
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Safety Requirements for Transporting Materials of Trade
Marking Requirements— Non-bulk packages (capacity of 119 gallons or less for liquids), other than cylinders, must be marked with the common name or proper shipping name of the material being carried.
1. The presence of the hazardous materials
2. The requirements of the Materials of Trade exceptions
Driver Requirements— DOT requires that the operator of a motor vehicle containing materials of trade be informed of the following:
Total Gross Weight Requirements— The total gross weight of all materials of trade carried on one motor vehicle cannot exceed 440 pounds
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Safety Requirements for Transporting Materials of Trade
Figure 3. Summary of Products Eligible for the Exceptions
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Safety Requirements for Transporting Materials of Trade
Penalty for Failure to Follow the Guidelines— If you fail to follow the guidelines for the materials of trade exceptions, you will be in violation of many requirements of the HMR and may be subject to significant fines and penalties. Currently the HMR allows for fines ranging from $250 to $27,500 per day, per violation. Criminal penalties can also be imposed on individuals directly involved with non-compliance.