INITIAL OSHA & DOT TRAINING
MODULE 9
Materials of Trade
INITIAL OSHA & DOT TRAINING
Module 9 – Materials of Trade Introduction
DOT has established Materials of Trade (MOT) exceptions
that allow companies to transport small quantities of certain
hazardous materials used in support of their primary
business. These materials must meet specific guidelines to
be classified as MOT.
Materials classified as MOT are exempted from many
regulations of the Hazardous Materials Regulations (HMR),
such as shipping papers, emergency response information,
or placarding, and do not require drivers to have any formal
training in handling them.
After completing this module, you will be able to explain:
 What qualifies as MOT.
 What hazard classifications can qualify for the MOT
exception.
 MOT quantity limitations and packaging
requirements.
 MOT marking and labeling requirements.
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INITIAL OSHA & DOT TRAINING
LESSON 1
What is a Material of Trade (MOT)?
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INITIAL OSHA & DOT TRAINING
Material of Trade Introduction
DOT defines MOT as limited quantities of a hazardous material, other
than a hazardous waste, that may be carried on a motor vehicle 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, such
as a spare battery or gasoline.
 Directly support the operations of the principal business, such
as landscaping, pest control, painting, plumbing, or welding
services.
In the propane industry, a common example of MOT is a bobtail driver
transporting a small container of methanol to assist in removing water
from within a propane tank.
Not all hazardous materials qualify for the MOT exception. Let’s review
the requirements for both hazard classification and quantities permitted.
LESSON 1
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INITIAL OSHA & DOT TRAINING
Classification Requirements
To be transported as MOT, the hazardous material must
belong to one of these specific classes or divisions:
 Flammable Gases such as acetylene and propane.
 Non-flammable Gases such as oxygen, nitrogen.
 Flammable and Combustible Liquids such as
gasoline, paint, paint thinner.
 Flammable Solids such as charcoal.
 Dangerous When Wet Materials such as some fumigants.
 Oxidizers such as hydrogen peroxide.
 Organic Peroxides such as benzoyl peroxide.
LESSON 1
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INITIAL OSHA & DOT TRAINING
Classification Requirements, cont.
 Poisons such as pesticides.
 Some Infectious Substances such as diagnostic specimens.
 Corrosive Materials such as muriatic acid, drain cleaners, and
battery acid.
 Miscellaneous Hazardous Materials such as asbestos and selfinflating lifeboats.
 Consumer Commodities such as hair spray and spray paints.
You may not deal with all of these hazard classes as part of your dayto-day job, but you should know what they are in case you are asked to
transport these MOT.
LESSON 1
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INITIAL OSHA & DOT TRAINING
Quantity Limits
The amount of hazardous mterial that can be transported
under the MOT exception is limited. Drivers must know the
capacity and weight of containers they are transporting to
ensure they are in compliance with the quantity limits. This is
especially important if more than one MOT is being
transported. The total gross weight of all MOT carried on one
motor vehicle cannot exceed 440 lb.
The following limits are based typically on hazard class
divisions and packing groups:
 If a material is a high-hazard material (Packing
Group I), the maximum amount in one package is one
pound for solids, or one pint for liquids.
 If the material is a medium- or lower-hazard material
(Packing Group II or III) with the exception of Division
4.3 and Consumer Commodities (ORM-D), the
maximum amount in each package is 66 lb for solids,
or 8 gallons for liquids.
LESSON 1
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INITIAL OSHA & DOT TRAINING
Quantity Limits, cont.
 For Division 4.3 materials (Packing Group II
and III), the maximum amount in each
package is one ounce.
 Each cylinder containing a gas (Division 2.1
or 2.2) may not weigh more than 220 lb.
 A diluted mixture of a Class 9 material may
be transported in a tank having a capacity of
up to 400 gallons.
LESSON 1
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INITIAL OSHA & DOT TRAINING
Packaging Requirements
According to DOT regulations, MOT must be packaged
in the following ways:
 Liquids and gases must be packaged in enclosed,
leak-proof containers and secured to prevent
movement or damage during transport.
 Cylinders used to transport Division 2.1
(Flammable Gas) or 2.2 (Non-flammable Gas)
MOT must conform to the packaging, qualification,
maintenance, and use requirements of the HMR,
except that outer packaging is not required.
 Manifolding cylinders are authorized if valves are
closed tightly.
 Gasoline must be in metal or plastic packaging and
conform to HMR and OSHA requirements.
LESSON 1
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INITIAL OSHA & DOT TRAINING
Packaging Requirements, cont.
 Materials must be packaged in their original
packaging, or in a package of equal strength
and quality.
 Nonbulk packaging, other than cylinders, must
be marked with the name of the material being
carried. DOT-specification cylinders must be
marked and labeled as required by the HMR.
NOTE: Outer packaging is not required for cans and
bottles secured in cages, carts, bins, boxes, or
compartments to prevent movement. However, they
cannot simply be placed in a can inside a bin. They must
be secured to prevent movement.
LESSON 1
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INITIAL OSHA & DOT TRAINING
Safely Transporting MOT
As with all hazardous materials, MOT must be
handled properly to minimize risk to yourself and
others. Treat all of these materials with the same care
and precaution you would if they were a placarded
load. A driver who does not comply with these
guidelines for transporting MOT may sustain fines
ranging from $275 to as much as $100,000 per day
as well as possibly face criminal penalties.
In addition to HMR requirements, you should also
follow any safety precautions present on the
material’s commercial packaging.
If you have any questions about how a particular
hazardous material should be handled or transported,
refer to its Material Safety Data Sheet (MSDS).
LESSON 1
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INITIAL OSHA & DOT TRAINING
LEARNING ACTIVITY
Identify Materials of Trade
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INITIAL OSHA & DOT TRAINING
MODULE 9 QUIZ
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