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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 #06-0154 ([Transportation Systems Solutions] [Mr. Peter Olsen])

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

Interpretation Response Details

Response Publish Date:

Company Name: Transportation Systems Solutions

Individual Name: Mr. Peter Olsen

Location State: IL Country: US

View the Interpretation Document

Response text:

Aug 8, 2006


Mr. Peter Olsen                 Reference No. 06-0154
Transportation Systems Solutions
318 Hampshire Lane
Crystal Lake, Illinois 60014

Dear Mr. Olsen:

This is in response to your June 27, 2006 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180) applicable to marking requirements for portable tanks. Specifically, you ask whether a portable tank marked with a proper shipping name of a hazardous material must also be marked with the United Nations (UN) identification number. In addition, you request a CFR citation that specifies the size of the marking of a proper shipping name on portable tanks. You further ask whether these requirements are applicable to all portable tanks transporting hazardous materials.

As required in § 172.326, a portable tank containing a hazardous material must be legibly marked on two opposing sides with the proper shipping name specified for the material in the § 172.101 Hazardous Materials Table (HMT). In addition, the name of the owner or of the lessee, if applicable, must be displayed on a portable tank that contains a hazardous material. As provided in § 172.302, markings must have a width of at least 4.0 mm (0.16 in) and a height of at least 25 mm (one inch) for portable tanks with capacities of less than 3,785 L (1,000 gallons). Markings on portable tanks with a capacity greater than 3,785 L (1,000 gallons) must have a width of at least 6.0 mm (0.24 inch) and a height of at least 50 mm (2.0 inches).

In addition, as required in § 172.302, a bulk packaging must be marked as required by
§ 172.332 with the identification number specified for the material in the HMT on each side and each end, if the packaging has a capacity of 3,785 L (1,000 gallons) or more; or on two opposing sides, if the packaging has a capacity of less than 3,785 L (1,000 gallons).

I trust this satisfies your inquiry.



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

172.302, 172.326

Regulation Sections

Section Subject
172.302 General marking requirements for bulk packagings.
172.326 Portable tanks