Interpretation Response #01-0212 ([Office of Motor Carrier Services] [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: Office of Motor Carrier Services
Individual Name: Mr. Michael Ritchie
Location State: MN Country: US
View the Interpretation Document
Response text:
October 19, 2001
Mr. Michael Ritchie Reference No. 01-0212
Office of Motor Carrier Services
Mail Stop 420
1110 Centre Pointe Curve
Medota Heights, MN 55120-4152
Dear Mr. Ritchie:
This is in response to your August 9, 2001 letter requesting clarification on an exemption issued under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 -1 80). Specifically, you ask about hazard communication requirements and exceptions for a tank constructed in accordance with DOT-E 1191 1. This exemption authorizes the construction and use of a 100 gallon capacity tank constructed in conformance with the requirements of a UN31A or UN31B intermediate bulk container (IBC) and allows the tank to be unloaded while on the motor vehicle.
You present a number of questions that all rely on one central issue: Are these 100 gallon tanks, built to an IBC specification, considered bulk or non-bulk containers? These tanks, built in accordance with DOT-E 11911, are considered non-bulk packages for the purpose of hazard communication and are eligible to be considered for exceptions for combustible liquids in non-bulk packagings under § 173.150(f) and placarding exceptions provided in § 172.504(c).
I hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
172.504, 173.150