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Interpretation Response #07-0184 ([Environmental Containment Solutions] [Mr. Roger Davies  ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Environmental Containment Solutions

Individual Name: Mr. Roger Davies  

Location State: CT Country: US

View the Interpretation Document

Response text:

OCT 29, 2007

Mr. Roger Davies                                   Ref. No. 07-0184


Environmental Containment Solutions

85 Research Drive

Stamford, CT 06906

Dear Mr. Davies:

This responds to your September 13, 2007 letter requesting information on IM-102 portable tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

In accordance with §173.32(c)(2), DOT Specification 51, IM-101 and IM-102 portable tanks may not be manufactured after January 1, 2003, but may continue in use provided they meet the requirements of the HMR in effect on September 30, 2001 or the new "T" codes in §172.102(c)(7)(i). In addition, the tank must pass periodic inspections and tests specified for the particular portable tank in Subpart G of Part 180. After January 1, 2003, all newly constructed portable tanks must conform to requirements for the design, construction and approval of UN portable tanks as specified in §§178.273, 178.274, 178.275, 178.276, 178.277 and Part 180, Subpart G, of the HMR.

I hope this answers your inquiry.


John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

172.102(c)(7)(i), 173.32(c)(2), 178.277

Regulation Sections

Section Subject
172.102 Special provisions
173.32 Requirements for the use of portable tanks
178.277 Requirements for the design, construction, inspection and testing of portable tanks intended for the transportation of refrigerated liquefied gases