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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #01-0027 ([Harmon Tank Company, Inc.] [Mr. Loy McGee])

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

Interpretation Response Details

Response Publish Date:

Company Name: Harmon Tank Company, Inc.

Individual Name: Mr. Loy McGee

Location State: TX Country: US

View the Interpretation Document

Response text:

FEB 9, 2001


Mr. Loy McGee                     Ref. No: 01-0027
Harmon Tank Company, Inc.
P.O. Box 2068
Lubbock, Texas 79408
Dear Mr. McGee:

This responds to your request for clarification of the periodic inspection and test requirements for non-specification cargo tanks authorized under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about inspection and retest requirements for non­specification cargo tanks authorized to transport flammable liquid petroleum products in intrastate commerce.

As you note, § 173.8 of the HMR permits an intrastate motor carrier to transport flammable liquid petroleum products in a non-specification cargo tank having a capacity of 3,500 water gallons or less provided the conditions listed in paragraph (d) of § 173.8 are met. Beginning July 1,2000, such non-specification cargo tanks must conform to all periodic test and inspection requirements applicable to DOT specification MC 306 cargo tanks, except for those listed in § 180.405(g) (see § 173.8(d)(6)). The non-specification cargo tank need not be retrofitted to meet the MC 306 specification, but operators must adhere to the same inspection and testing schedule as outlined for an MC 306 specification cargo tank. The operator must complete only the inspections and tests applicable to the tank itself and the equipment and appurtenances installed on the tank. In the example you provide, a non-specification cargo tank that is not equipped with self-closing stop valves, remote closures, or similar emergency devices and valves is not required to meet the inspection and testing requirements applicable to such devices.

I hope this information is helpful. If you have any questions, please do not hesitate to contact this office.



Thomas G. Allan
  Senior Transportation Regulations Specialist
  Office of Hazardous Materials Standards


Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks