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Interpretation Response #12-0053 ([Blue Sky Technologies] [Mr. Charley Simpson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Blue Sky Technologies

Individual Name: Mr. Charley Simpson

Location State: TX Country: US

View the Interpretation Document

Response text:

May 9, 2012



Mr. Charley Simpson
Blue Sky Technologies
396 CR 4929
Newark, TX 76071

Ref. No. 12-0053

Dear Mr. Simpson:

This responds to your February 9, 2012 request requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter, your company uses liquefied petroleum gas (LPG) propane fuel tanks that fuel your desiccant drying units which are trailer mounted drying machines with burners fueled by propane. These drying machines are fueled by 4 separate DOT420 tanks with a capacity of 100 gallons per tank and are permanently mounted and hard plumbed together for the sole purpose of fueling your trailer mounted drying machines. You state that our Hazardous Materials Information Center (HMIC) informed you do not have to placard your vehicle based on our previous interpretation letter Ref. No. 11-0181. Specifically, you request confirmation that interpretation letter Ref. No. 11-0181 is applicable to your tanks.

Based on the information you provide, interpretation letter Ref. No. 11-0181 is applicable to your tanks. It is the opinion of this office that the tanks you describe are fuel tanks and are not subject to the HMR. Fuel systems that meet the requirements under 49 CFR 393.65 and 393.67 of the Federal Motor Carrier Safety Regulations (FMCSR) and are not used as packaging for hazardous materials are subject only to the FMCSR.

I hope this answers your inquiry. If you need additional assistance, please contact this office at 202-366-8553.



Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
171.8 Definitions and abbreviations