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Interpretation Response #04-0206 ([Mississippi Tank Company] [Mr. Mike Pitts])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mississippi Tank Company

Individual Name: Mr. Mike Pitts

Location State: MS Country: US

View the Interpretation Document

Response text:

Mar 18, 2005


Mr. Mike Pitts                  Reference No. 04-0206
Vice President/Sales
Mississippi Tank Company
P.O. Drawer 1391
Hattiesburg, MS 39403-1391

Dear Mr. Pitts:

This responds to your letter to Mr. Danny Shelton, Federal Motor Carrier Safety Administration, concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of MC 331 cargo tanks marked or certified after October 1, 2004. Specifically, you ask if the requirements concerning metal name plates and specification plates apply to the cargo tank or to the cargo tank motor vehicle (CTMV).  I apologize for the delay in responding and any inconvenience it may have caused.

In accordance with § 178.337-17, an MC331 cargo tank certified after October 1, 2004, must have a metal name plate (also referred to as an ASME plate) permanently attached to the cargo tank. In addition, an MC331 cargo tank motor vehicle certified after October 1, 2004, must have a specification plate that includes the information specified in § 178.337-17(c). You are correct that, as currently written, § 178.337-17 is not clear as to these requirements. We will clarify the name plate and specification plate requirements in a future rulemaking.

You also asked if the HMR require the cargo tank assembler’s CT number to be included on the specification plate. Currently, the CT number is not required to be shown on the specification plate.

I hope this satisfies your inquiry. If you have further questions, please do not hesitate to contact this office.



John A. Gale
Chief, Standard Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
178.337-17 Marking