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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 #01-0287 ([Citgo Petroleum Corporation] [Mr. John Montou])

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

Interpretation Response Details

Response Publish Date:

Company Name: Citgo Petroleum Corporation

Individual Name: Mr. John Montou

Location State: TX Country: US

View the Interpretation Document

Response text:

January 8, 2002


Mr. John Montou                          Reference  No. 01-0287
Terminal Manager
Citgo Petroleum Corporation
301 Terminal Road
Fort Worth, Texas 76106

Dear Mr. Montou:

This responds to your October 30, 2001 letter requesting clarification on recordkeeping requirements for cargo tank test reports under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether your terminal is required to verify that the tests were performed and if it is required to retain a copy of the test results.

According to your letter your terminal does not own, lease or operate any vehicles that transport gasoline and/or diesel, that are supplied by the motor carrier.  The drivers of the transport vehicles perform the loading of the product into the truck and a bill of lading is issued after the transfer is complete.  Recordkeeping provisions under § 180.417(b) require that the owner of a specification cargo tank and the motor carrier, if not the owner, must each retain a copy of the test and inspection reports until the next test or inspection of the same type is successfully completed.  This requirement does not apply to a motor carrier leasing a cargo tank for less than 30 days or to your terminal if you do not own or lease the cargo tank.

I hope this answers your inquiry.



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


Regulation Sections

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