Interpretation Response #26-0103
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:
October 14, 2026
Greg Miller
Lead Safety & Technical Trainer
Thompson Gas
8895 Canyon River Court
Sparks, NV 89434
Reference No. 26-0103
Dear Mr. Miller:
This letter is in response to your July 14, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of ASME propane storage containers, with respect to requirements for consumer storage containers, specifically, § 173.315(j)(2). You note that § 171.8 defines neither "storage container" nor "consumer storage container." You also present a transport scenario involving an ASME storage container that: (1) does not exceed 500 gallons water capacity; (2) contains more than 5 percent propane; (3) is being transported by a private motor carrier; and (4) is being moved one way from the consumer's premises to the container owner's nearest facility and ask several related questions.
We have paraphrased and answered your questions as follows:
Q1. What does the phrase "only one storage container" mean in the context of § 173.315(j)(2)(iv)?
A1. As you correctly noted, the HMR does not specifically define "(consumer) storage container" in § 171.8. However, the phrase "only one storage container" means a single consumer storage container intended for permanent installation on consumer premises and does not refer to HMR authorized transport packagings, such as a DOT specification cylinder.
Q2. Under § 173.315(j)(2), may a transport vehicle carrying one qualifying ASME consumer propane storage container containing more than 5 percent propane under the applicable transportation exception also transport one or more DOT specification propane cylinders (e.g., a 100-lb. propane cylinder)?
A2. Yes. Section 173.315 does not prohibit, or otherwise address, the transportation of additional hazardous materials packages, such as a DOT specification cylinder filled with propane, on the same vehicle. Such transportation is authorized, as long as all applicable transportation requirements (e.g., segregation) are met. However, note that the intent of § 173.315(j) is to allow for limited movement of consumer propane storage containers, which are not otherwise authorized for transportation, without having to first empty the tanks. Further, while § 173.315(j) does not prohibit other hazardous materials packages on the vehicle, (j)(2) specifies one-way movement from the consumer to the owner's nearest facility, such that intermediate stops for dropoffs or pickups are not allowed.
Q3. If additional DOT specification propane cylinders are transported on the same vehicle as the consumer storage container, does it make a difference whether the DOT specification cylinders contain propane products or only propane residue? If so, how does the presence of product versus residue affect the interpretation or application of § 173.315(j)(2)(iv)?
A3. No. Generally, empty packagings containing only the residue of a hazardous material are treated in the same manner as when filled. See § 173.29 for further information on requirements for empty packagings.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards and Development Branch
Standards and Rulemaking Division