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Interpretation Response #09-0053

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

Interpretation Response Details

Response Publish Date: 11-13-2009
Company Name: Trimac Transportation & National Tank Truck Carriers, Inc.    Individual Name: Mr. Rattan Bahia & Mr. John Conley
Country: CA

View the Interpretation Document

Response text:

November 13, 2009



Mr. Rattan Bahia
Trimac Transportation
1700 800 5th Avenue S.W.
P.O. Box 3500
Calgary, Alberta
T2P 2P9

Mr. John Conley

National Tank Truck Carriers, Inc.
950 North Glebe Road, Suite #520
Arlington, VA 22203-4183

Reference No. 09-0053

Dear Messrs. Bahia and Conley:

This is in response to Mr. Bahia's two January 28, 2009 e-mails to Mr. John Conley, President, National Tank Truck Carriers, Inc., and Mr. Conley's February 26, 2009 e-mail forwarding Mr. Bahia's e-mails to the U. S. Department of Transportation's (DOT's) Federal Motor Carrier Safety Administration (FMCSA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA). You ask if a DOT specification cargo tank that is used wholly within Canada or in cross-border service may be repaired in Canada in accordance with the Canadian Standards Association B620 by a Transport Canada registered facility that does not have a National Board Certificate of Authorization for the use of the "R" stamp or a DOT "CT" number.

The answer is no. In accordance with 49 CFR 107.502(b), no person may engage in the manufacture, assembly, certification, inspection, or repair of a cargo tank or cargo tank motor vehicle manufactured under the terms of a DOT specification or a DOT special permit unless the person is registered with FMCSA's Hazardous Materials Division in the manner prescribed in 49 CFR Part 107, Subpart F. FMCSA assigns each registered person a "CT" registration number. In addition, § 107.503(c) requires each person who repairs a DOT specification or special permit cargo tank or cargo tank motor vehicle to submit a copy of the repair facility's current National Board Certificate of Authorization for the use of the "R" stamp (or an ASME Certificate of Authorization for the use of the ASME "U" stamp). Also, the definitions for a cargo tank "registered inspector," prescribed in § 171.8, and cargo tank "manufacturer," prescribed in § 178.320, require that both must register with the DOT in conformance with 49 CFR Part 107, Subpart F. Also, note that in accordance with § 171.12, cargo tank periodic retests and inspections required by § 173.33 may be performed in accordance with 49 CFR Part 180 or Transport Canada's Transportation of Dangerous Goods (TDG) regulations provided the intervals prescribed in Part 180 are met.

I hope this satisfies your request.


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

107.502(b), 178.320

Regulation Sections

Section Subject
§ 171.12 North American Shipments