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Interpretation Response #02-0307 ([Mark Rite Lines Equipment Company, Inc.] [Milo A. Thomas])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mark Rite Lines Equipment Company, Inc.

Individual Name: Milo A. Thomas

Location State: MT Country: US

View the Interpretation Document

Response text:

Dec 20, 2002

Mr. Milo A. Thomas                 Reference No. 02-0307
Mark Rite Lines Equipment Company, Inc.
5379 Southgate Drive
Billings, MT 59107-1154

Dear Mr. Thomas:

This is in response to your letter dated November 12, 2002, requesting clarification on the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to your "highway striping vehicle" with propane tanks permanently mounted to the truck.  Specifically, you request clarification of the placarding requirements for your highway striping vehicle that is equipped with a large permanently mounted propane tank used to supply fuel to auxiliary equipment.

It is the opinion of this office that if the propane tank meets the requirements for all fuel systems under §§ 393.65 and 393.69 of the Federal Motor Carrier Safety Regulations (FMCSR), including marking, and is maintained in accordance with the National Fire Protection Association's and the American Society of Mechanical Engineers' standards for fuel systems, and not used as a packaging for hazardous materials, e.g., a cargo tank, then the tank is subject only to the FMCSR and as such the vehicle would not be required to be placarded.  However, if the tank does not meet the FMCSR requirements for fuel systems, then the fuel tank would depending on size meet the definition of a non-bulk or bulk packaging (see § 171.8). Under the HMR, propane in a non-bulk or bulk packaging is subject to specification packaging, shipping papers, marking, placarding, and emergency response information requirements.

I hope this information is helpful.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.8 Definitions and abbreviations