What are Materials of Trade, and why should you care?

In last week’s post about non-hazmat employees who should receive hazmat training, Labelmaster Director of Global Learning Rhonda Jessop recommended 49 CFR training for employees who transport “Materials of Trade,” which she defined as:

specific amounts of regulated substances that are transported for use on the job, such as painters carrying commercial-sized containers of paint from a warehouse to a job site.”

That’s an element of hazmat transport we don’t talk about very often, because it’s outside what we generally think of as the supply chain. Once your hazmat item reaches its end user, we’re no longer talking about Dangerous Goods transport, right?

Actually, we are. As Jessop points out, the 49 CFR does address Materials of Trade. More importantly, these materials still pose a safety risk when transported—whether it’s from a supplier to an end user or just from one job site to another—so it’s important that hazmat professionals know the rules governing them.

Let’s take a closer look at regulations regarding Materials of Trade. (For a more detailed examination, download this pamphlet from PHMSA.)

What are Materials of Trade? How are they regulated?

Materials of Trade regulations apply only to highway transport, only to hazardous materials (not hazardous waste) and only when those materials are being carried for any of three basic reasons:

  1. To protect the health and safety of the vehicle’s operator or passengers; e.g., insect repellent or a fire extinguisher
  2. To support the operation or maintenance of the vehicle or its equipment; e.g., a spare battery or extra gasoline
  3. To directly support the principal business of the vehicle’s operator

Of these, #3 is the one most likely to concern business operators, since such materials could include those carried for landscaping, pest control, painting, plumbing, welding services or any number of other businesses.

Some common Materials of Trade are propane, paints, gasoline, charcoal, some fumigants, pesticides, drain cleaners, battery acids and certain consumer commodities. Substances and items from nearly every hazmat class can be classified as Materials of Trade.

How are Materials of Trade regulations different?

Generally speaking, Materials of Trade regulations (as defined in 49 CFR Section 173.6) are less burdensome than hazmat transport regulations. Materials of Trade, for instance, do not require:

  • Shipping papers
  • Emergency response information
  • Placarding
  • Formal training
  • Retention of training records

However, Materials of Trade are still subject to quantity limitations, packaging requirements, and marking and labeling requirements. Naturally, these vary sharply depending on the hazmat class in question, their required packing groups and numerous other variables.

With a single exception—tanks containing diluted mixtures of Class 9 materials—a single vehicle may not transport more than 440 pounds of any Materials of Trade (combined gross weight).

Why are Materials of Trade regulations and training important?

A hazardous material is hazardous anytime it’s transported.

However, businesses that don’t regularly engage in the transport of Dangerous Goods may not be fully aware of those hazards. They’re not set up for hazmat compliance, and they’re less likely to have their awareness triggered by compliance-related business interruptions or penalties.

Business operators—especially smaller ones—may not even be aware there are regulations governing the transport of these materials from warehouse to job site, or from one job site to another. They may not employ anyone with sufficient hazmat training to recognize the risks and hazards involved.

In short, people’s safety may be jeopardized.

That’s why we’d like to see more businesses pursue 49 CFR training for their employees who transport Materials of Trade, even if that training isn’t required by law. Knowing the rules—and complying with them—will keep more workers safe, and that’s all that really matters.


Labelmaster is a full-service provider of goods and services for hazardous materials and Dangerous Goods professionals, shippers, transport operators and EH&S providers. See our full line of solutions at labelmaster.com.

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One Comment;

  1. Jeff Christafore said:

    Definitely a good idea to train employees on the requirements of Materials of Trade. I have been providing training on this topic to the employees I train for many years even though it is not required by law. In addition to an Company LMS training platform I utilize to provide the training, I also created a Materials of Trade Procedure to provide employees with more information. There is also a DOT Letter of Interpretation (12-0060) on file for questions I had concerning MOT in regards to company operations.

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