Our salesman takes samples to prospective clients. Are the samples subject to hazardous materials regulations?
A common misconception is that the DOT doesn’t regulate small amounts of materials. However, just because it’s a “small amount” doesn’t mean that it’s excluded from the DOT’s hazardous materials regulations. As with shipping any material, you must first determine whether the material meets the definition of any DOT hazard class. For example, if it is a liquid with a flash point less than 141 degrees Fahrenheit, it is Class 3, flammable liquid. If it can destroy skin tissue, it is Class 8, corrosive. If the material does not meet the definition of any DOT hazard class, then you don’t have to worry about the hazardous materials regulations. As a general rule, the DOT expects you to be correct in classifying your material’s hazards. If the material is a hazardous material, you may be able to use the special rules for “materials of trade,” found at 49 CFR 173.6. Under §173.6, small quantities of “materials of trade” in certain hazard classes may be transported by motor vehicle without usin
