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Interpretation Response #07-0208 ([American Metals & Chemical Corporation] [Mr. Barry D. Reichenberg])

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

Interpretation Response Details

Response Publish Date:

Company Name: American Metals & Chemical Corporation

Individual Name: Mr. Barry D. Reichenberg

Location State: FL Country: US

View the Interpretation Document

Response text:

February 21, 2008

Mr. Barry D. Reichenberg

American Metals & Chemical Corporation

P.O. Box 1048

Dania, FL 33004

Reference No. 07-0208

Dear Mr. Reichenberg:

This is in response to your October 15, 2007 letter to Mr. Charles Hochman, Director, Office of Hazardous Materials Technology, Pipeline and Hazardous Materials Safety Administration, U.S. Department of Transportation (DOT), and your November 1, 2007, and November 11, 2007, telephone conversations with Ms. Eileen Edmonson of my staff. You asked if a 20-foot long, atmospheric pressure, 5,000-6,000 gallon capacity, International Standards Organization (ISO) tank in a box or beam type frame is a portable tank or cargo tank under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Mr. Hochman forwarded your letter to the Office of Hazardous Materials Standards for response.

An ISO tank in a framework is a portable tank under the HMR. The portable tank must meet the T-Codes listed in § 172.102(c)(7) for the hazardous material it contains. Fitted with structural equipment, mountings, or accessories to facilitate mechanical handling, this tank is typically used for intermodal and international transport. See "Intermodal portable tank," "Portable tank," and "UN portable tank" under § 171.8. After January 1, 2003, all newly manufactured portable tanks must conform to the requirements for the design, construction, and approval of UN portable tanks specified in §§ 178.273, 178.274, 178.275, 178.276, 178.277, and 49 CFR Part 180, Subpart G. See § 173.32(c)(2). The HMR prescribe additional requirements for the use of DOT specification and UN portable tanks in § 173.32.

You state you are considering transporting "UN 2586, Alkyl sulfonic acids, liquid, 8 (corrosive), PG III" in an ISO tank. Please note that Column 7 of the Hazardous Materials Table (HMT; § 172.101) for this material requires you to use a tank that conforms to the

minimum shell thickness and maximum degree of filling requirements prescribed in Special Provisions T4 and TP1, respectively. See §§ 172.102(c)(7)(ii) and (c)(8)(ii), and 178.274(d)(2).

I hope this satisfies your request.


Hattie L. Mitchell, Chief

Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.326, 172.328, 172.101, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.101 Purpose and use of hazardous materials table
172.326 Portable tanks
172.328 Cargo tanks