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Interpretation Response #04-0067 ([Sauer Express, Inc.] [Ms. Connie Sauer])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sauer Express, Inc.

Individual Name: Ms. Connie Sauer

Location State: KY Country: US

View the Interpretation Document

Response text:

Mar 30, 2004


Ms. Connie Sauer                Reference No. 04-0067
Sauer Express, Inc.
3202 Renwood Blvd., #203
Louisville, KY 40214

Dear Ms. Sauer:

This is in response to your March 19, 2004 letter requesting clarification regarding cargo tank inspections and tests required under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about testing and marking requirements for unlined cargo tanks that are tested and marked in accordance with § 180.407(i). In your letter, you state that a Michigan State Patrol Officer issued a violation to your company for failing to perform the required periodic thickness test on your cargo tank.

Section 180.407(i) establishes thickness testing requirements for unlined cargo tanks.  Generally, the shell and head thickness of all unlined cargo tanks used for the transportation of materials corrosive to the tank must be measured at least once every 2 years.  Although your tank was initially tested and marked in accordance with § 180.407(i), there is no requirement to periodically perform this test when no materials corrosive to the tank are being transported.  Additionally, the HMR do not require that thickness testing markings that are no longer applicable be covered during transportation.  However, we recommend that to prevent future frustration of your shipments that you cover the thickness marking, when these markings are not applicable.

I hope this information is helpful.  If you have additional questions, please do not hesitate to contact this office.



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


Regulation Sections

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