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Interpretation Response #10-0054

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

Interpretation Response Details

Response Publish Date: 05-07-2010
Company Name: National Oilwell Varco    Individual Name: Dr. Jianke Wang
Location state: TX    Country: US

View the Interpretation Document

Response text:

May 7, 2010





Dr. Jianke Wang
Senior Project Manager
National Oilwell Varco
2800 N. Frazier St.
Conroe, TX 77303

Ref. No. 10-0054

Dear Dr. Wang:

This responds to your March 5, 2010 email and subsequent telephone discussion with a member of my staff regarding requirements for the continued use of DOT Specification IM 101 and 102 portable tanks for transportation of diesel fuel, with a flashpoint of about 140°F, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about the impact of the transitional period provided in § 171.14(d)(4) after January 1, 2010. You state these IM portable tanks will be in full conformance with the requirements in § 173.32(c)(2) and will occasionally be transported by vessel to offshore drilling sites.

The obsolete provision in § 171.14(d)(4) allowed for a hazardous material to be transported until January 1, 2010 in an IM portable tank in accordance with the T codes (special provisions) assigned to the hazardous material in the § 172.101 Hazardous Materials Table (HMT) in effect on September 30, 2001. IM portable tanks now are required to meet the applicable special provisions appearing in the current HMT.

Diesel fuel, UN1202, is listed in the HMT and assigned Special provisions B1, T2 and TP1 in Column (7). The B1 code provides that, for a hazardous material with a flashpoint between 100°F and 200°F, the bulk packagings listed in § 173.241 may be used. Paragraph (c) of that section authorizes use of IM portable tanks. The T2 code specifies the tank"s minimum test pressure, minimum shell thickness, bottom opening and pressure relief requirements. The TP1 code prescribes filling density requirements. These specific code requirements are contained in § 172.102(c)(7) and (c)(8), respectively.

I hope this information is helpful. If you have further questions, please contact this office.


Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards

171.14, 173.32, 172.102

Regulation Sections

Section Subject
§ 176.340 Combustible liquids in portable tanks