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Interpretation Response #03-0047 ([Halliburton Energy Services] [Mr. Johnny Cathey])

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

Interpretation Response Details

Response Publish Date:

Company Name: Halliburton Energy Services

Individual Name: Mr. Johnny Cathey

Location State: OK Country: US

View the Interpretation Document

Response text:

May 13, 2003


Mr. Johnny Cathey                Reference No. 03-0047
Halliburton Energy Services
Health, Safety, & Environment
2600 South 2nd Street
Duncan, OK 73536-0431

Dear Mr. Cathey:

This responds to your February 13, 2003 letter requesting clarification on marking requirements in § 172.336(c)(1) in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Specifically, you ask if your proposed multi-tank cargo tank motor vehicle (CTMV) configuration is eligible for provisions in § 172.336(c)(1) concerning identification number display.

According to your letter and enclosed drawing, your proposed CTMV will consist of 10 independently mounted cargo tanks on a trailer chassis, with 5 tanks mounted on each side for use in the oil and natural gas exploration industry.  The tanks will have capacities ranging from 150 to 500 gallons.  You ask if this design configuration would require that each tank display identification numbers on all four sides or would provisions in § 172.336(c)(1) be authorized.

It is the opinion of this Office that your proposed multi-tank CTMV is comprised of separate cargo tanks and is not a “compartmented” cargo tank as referenced in § 172.336(c)(1). Therefore, the provisions of § 172.336(c)(1) do not apply.

I hope this answers your inquiry.



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


Regulation Sections

Section Subject
172.336 Identification numbers; special provisions