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Interpretation Response #08-0171 ([Hoyt and Blewett PLLC] [Mr. Drew Blewett])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hoyt and Blewett PLLC

Individual Name: Mr. Drew Blewett

Location State: MT Country: US

View the Interpretation Document

Response text:

February 23, 2009

Mr. Drew Blewett

Hoyt and Blewett PLLC

P.O. Box 2807

Great Falls, MT 59403

Ref. No. 08-0171

Dear Mr. Blewett:

This responds to your June 24, 2008 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to fuel tanks permanently mounted on a motor vehicle. Specifically, you ask if four 119-gallon tanks permanently mounted on the bed of a truck and connected together with permanently mounted fuel lines meets the definition for a non-bulk packaging in § 171.8 of the HMR.

The answer is no. For purposes of the HMR, the fuel tank configuration described in your letter is considered a single bulk packaging with a capacity of 476 gallons. The unit does not meet the definition of "non-bulk packaging" due to its overall capacity. Please note that, under the HMR, the fuel tank configuration described in your letter meets the definition for a cargo tank and must meet all applicable HMR requirements if used to transport hazardous materials. See § 171.8 for the definition of "cargo tank."

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.8 Definitions and abbreviations