Interpretation Response #10-0120 ([Minnesota Department of Transportation Office of Freight and Commercial Vehicle Operations] [Mr. Michael Ritchie])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Minnesota Department of Transportation Office of Freight and Commercial Vehicle Operations
Individual Name: Mr. Michael Ritchie
Location State: MN Country: US
View the Interpretation Document
Response text:
July 12, 2010
Mr. Michael Ritchie
Minnesota Department of Transportation
Office of Freight and Commercial Vehicle Operations
395 John Ireland Blvd.
St. Paul, MN 55155-1899
Ref. No. 10-0120
Dear Mr. Ritchie:
This responds to your June 4, 2010 letter regarding placarding and marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask questions regarding the display of markings and placards on a wagon trailer with two nurse tanks mounted side by side (i.e., a twin-tank farm trailer). Your letter includes photographs illustrating the twin-tank farm trailers. The capacity of the twin nurse tanks ranges from 1,000 to 1,450 gallons. Your questions are paraphrased and answered as follows:
Q1. Are markings and a placard required on the adjacent sides (i.e., the interior sides facing each tank) of the twin nurse tanks that are not visible from the direction they face?
A1. Yes. As a bulk packaging, a nurse tank must be marked and placarded on each side (and each end). See §§ 172.302, 172.328, and 172.504 of the HMR.
Q2. If appurtenances (e.g., valves, fittings, etc.) on the end of a nurse tank prevent markings and a placard from being properly placed and visible on the tank, is that same end of the wagon trailer to which the nurse tank is mounted required to be marked and placarded?
A2. No. In accordance with § 173.315(m), a nurse tank is not required to be marked and placarded on one end when appurtenances on that end obstruct proper placement and visibility. The provisions of § 173.315(m) include securely mounting the nurse tank to a wagon trailer. Thus, it is the opinion of this Office that this exception also applies to the end of the wagon trailer. Note that with regard to the photographs of the twin-tank farm trailer, the end of the
nurse tank with appurtenances is not obstructed sufficiently to prevent proper placement and visibility of markings and a placard.
I hope this information is helpful. If you have further questions, please contact this office.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.315
Regulation Sections
| Section | Subject |
|---|---|
| 173.315 | Compressed gases in cargo tanks and portable tanks |