Interpretation Response #02-0163

Interpretation Response Details

Jul 10, 2002

Mr. Michael G. Merrill                 Reference No. 02-0163
Director, Safety and Training Services
Suburban Propane
240 Route 10 West
Whippany, NJ 07981-0206

Dear Mr. Merrill:

This is in response to your May 29, 2002 letter, requesting concurrence that the addition of your website address to your existing company logo on cargo tank motor vehicles, meets the intent of § 178.337-1(d) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you state that the black letters of your website address would be located below your existing red stripe and on the lower half of the cargo tank as shown in the enclosed photograph.  You indicate that the website address is approximately 0.33 square feet of the total 293 square foot surface area of the cargo tank.

As defined in § 178.337-1(d), every uninsulated cargo tank permanently attached to a cargo tank motor vehicle shall, unless covered with a jacket made of aluminum, stainless steel, or other bright non-tarnishing metal, be painted a white, aluminum or similar reflecting color on the upper two-thirds of area of the cargo tank.

It is the opinion of this Office that the addition of your website address to your existing company logo on the cargo tanks, as shown in the photograph you supplied, does not conflict with § 178.337-1 (d); therefore, you appear to be in compliance with that section.

I hope this information is helpful.  If we can be of further assistance, do not hesitate to contact us.

Sincerely,

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

178.337-1(d)

Regulation Sections