Interpretation Response #25-0147
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Thompson Gas
Individual Name: Greg Miller
Location State: NV Country: US
View the Interpretation Document
Response text:
March 24, 2026
Greg Miller
Lead Safety & Technical Trainer
Thompson Gas
8895 Canyon River Ct.
Sparks, NV 89434
Reference No. 25-0147
Dear Mr. Miller:
This letter is in response to your October 27, 2025 letter and subsequent phone conversations with my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to bulk packaging. Specifically, you ask whether a 120-gallon American Society of Mechanical Engineers (ASME) propane container is bulk or non-bulk by water weight as a receptacle for a gas, as specified by 49 CFR § 171.8.
The definition of a bulk packaging in § 171.8 states that a container with a water capacity greater than 454kg (1000 pounds) as a receptacle for a gas, as defined in 49 CFR [SA1]§ 173.115, is a bulk packaging. If the information you provided in your calculation is accurate and the container is exactly 120 gallons with a 1000.8lb water weight capacity, then the container would be a bulk packaging. You also asked whether the container was bulk by kilograms instead of pounds. PHMSA notes that § 171.10(c)(2) provides conversion rates between the International System of Units (SI) and U.S. standard measurements. [JN2][AW3][SA4]
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
171.8; 171.10(c)(2); 173.115