USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #10-0116 ([NW Natural] [Mr. Neil Banman])

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

Interpretation Response Details

Response Publish Date:

Company Name: NW Natural

Individual Name: Mr. Neil Banman

Location State: OR Country: US

View the Interpretation Document

Response text:

May 12, 2011




Mr. Neil Banman

Attorney at Law

NW Natural

220 NW 2nd Avenue

Portland, OR 97209

Reference No. 10-0116

Dear Mr. Banman:

This is in response to your letter and e-mail and subsequent telephone conversation with a member of my staff asking if a tube trailer motor vehicle is one bulk packaging that requires a security plan under § 172.800 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter, you state your company has two tube trailer motor vehicles that each contain 54 DOT specification cylinders that are permanently mounted lengthwise to a frame attached to the vehicle"s chassis. You provided a photograph of one of the trailers. You also state these cylinders have a capacity of 65 gallons each; their own shut-off valve that is closed during transport; and each is connected with stainless steel tubing through a header, heat exchanger, and several additional valves to an automated valve that controls outlet pressure. We apologize for the delay in responding and any inconvenience this may have caused.

Based on the information you provided, the tube trailer you describe is a bulk packaging because it is a transport vehicle, as this term is defined under § 171.8, and has a quantity of gas exceeding 3,000 L (792 gallons), which meets the definition of a large bulk packaging as this term is defined in § 172.800(b). Therefore, it is required to have an in-depth security plan in conformance with § 172.800(b) of the HMR after October 1, 2010 (see Docket No. PHMSA-06-25885 (HM-232F), 3/9/10, 75 FR 10974). The tube trailer is also one packaging because its cylinders are coupled together through piping and a manifold. The presence of a shut-off valve and pressure relief device on each cylinder of a tube trailer do not alter the tube trailer"s designation as one packaging because: 1) the cylinders can be filled with or release gas simultaneously; and 2) a malfunctioning or inoperable valve and the resulting gas released could cause other valves in the packaging to malfunction or fail and, depending on the type of gas released, may cause the failure of the entire package.

I hope this satisfies your request.


Charles E. Betts

Director, Standards and

Rulemaking Division

172.800, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.800 Purpose and applicability