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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #05-0012 ([Mr. Bob Thompson] [Mr. Bob Thompson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mr. Bob Thompson

Individual Name: Mr. Bob Thompson

Location State: KY Country: US

View the Interpretation Document

Response text:

Feb 17, 2005


Mr. Bob Thompson                Reference No. 05-0012
United Propane Gas Companies, Inc.
4200 Cairo Road
Paducah, Kentucky 42002-2450

Dear Mr. Thompson:

This responds to your January 18, 2005 letter and subsequent telephone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the proper shipping name must be marked on the outside of a cargo tank in addition to the required placards and identification number markings for ammonia anhydrous and propane.

The answer is yes. A cargo tank containing a Class 2 material must be marked in accordance with Part 172, Subpart D and placarded in accordance with Part 172, Subpart F. A cargo tank containing a Class 2 material must be marked with the proper shipping name specified in the Hazardous Materials Table (HMT; § 172.101), or an appropriate common name for the material (e.g., “Refrigerant Gas”) in accordance with § 172.328. However, § 172.328 provides an exception from the requirement to mark the proper shipping name or common name on certain nurse tanks that are marked in accordance with § 173.315(m).

I hope this information is helpful. Please contact us if you require additional assistance.



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

172.328, 172.334, 172.519

Regulation Sections

Section Subject
172.328 Cargo tanks
172.334 Identification numbers; prohibited display
172.519 General specifications for placards