Interpretation Response #14-0180 ([Countryside Tank] [Mr. Joe Greving])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 02/10/2015

Company Name: Countryside Tank

Individual Name: Mr. Joe Greving

Location State: IA Country: US

View the Interpretation Document

Response text:

February 10, 2015

Mr. Joe Greving
Countryside Tank
Division of Iowa Steel Fabrication, LLC
1525 East Eddy Saylor Parkway
Osceola, IA  50213

Reference No. 14-0180

Dear Mr. Greving:

This is in response to your September 24, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the general requirements for specification MC 331 cargo tanks.  Your questions are answered as follow:

Q1.  What is the definition of “similar reflecting color” as specified in § 178.337-1(d)(4)?

A1.  The HMR does not provide a specific definition for the term “similar reflecting color.”  

Q2.  Are there specific paint properties and/or colors that you can provide that would meet the requirements of the HMR?

A2.  The HMR does not specify paint properties or colors that would be deemed as a “similar reflecting color.”

Q3.  Is the trailer color scheme presented in conformance with the requirements of the HMR?

A3.  It is the opinion of this Office that since the majority of the color on the upper two thirds of the cargo tank is white or silver and that there is a limited amount of the light orange/red color, that the paint scheme on the cargo tank would be in compliance with § 178.337-1(4)(d).

I trust this information is helpful.  If you have further questions, please do not hesitate to contact this office.
Sincerely,

Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division
178.337-1(d)(4), 178.337-1(4)(d)

Regulation Sections