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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.

Sincerely,

 

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)