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Interpretation Response #05-0051 ([Georgia Department of Motor Vehicle Safety] [Capt. Bruce Bugg])

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

Interpretation Response Details

Response Publish Date:

Company Name: Georgia Department of Motor Vehicle Safety

Individual Name: Capt. Bruce Bugg

Location State: GA Country: US

View the Interpretation Document

Response text:

Mar 22, 2005

 

Capt. Bruce Bugg                      Reference No. 05-0051

Law Enforcement Division
Georgia Department of Motor Vehicle Safety
P.O. Box 80447
Conyers, GA 30013-8047

Dear Capt. Bugg:

This responds to your electronic mail requesting clarification under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) of the marking requirements for certain bulk packagings. Specifically, you ask whether a bulk packaging that is dual marked as a DOT specification intermediate bulk container (IBC) and a DOT specification portable tank is required to be marked with the identification number as required in § 172.331 for IBCs, or the proper shipping name, the name of the owner or lessee, and the identification number as required in § 172.326 for portable tanks.

An IBC must be marked with the identification number in accordance with § 172.331 and a portable tank must be marked with the proper shipping name, the name of the owner or lessee, and the identification number in accordance with § 172.326. Therefore, to satisfy the marking requirements, the dual-marked bulk packaging must be marked with the proper shipping name, the name of the owner or lessee, and the identification number as specified in § 172.326. Also, the bulk packaging must conform to all applicable specification requirements and be authorized for the hazardous material being transported.

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

Sincerely,

 

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

172.326, 172.331

Regulation Sections

Section Subject
172.326 Portable tanks
172.331 Bulk packagings other than portable tanks, cargo tanks, tank cars and multi-unit tank car tanks