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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.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

172.504, 173.150

Regulation Sections

Section Subject
172.504 General placarding requirements
173.150 Exceptions for Class 3 (flammable and combustible liquids)