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Interpretation Response #12-0055 ([J. J. Keller & Associates, Inc.] [Mr. Tom Ziebell Sr.])

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

Interpretation Response Details

Response Publish Date:

Company Name: J. J. Keller & Associates, Inc.

Individual Name: Mr. Tom Ziebell Sr.

Location State: WI Country: US

View the Interpretation Document

Response text:

March 30, 2012



Mr. Tom Ziebell
Sr. Hazmat Editor
J. J. Keller & Associates, Inc.
3003 Breezewood Lane
P. O. Box 368
Neenah, WI 540957"0368

Ref. No.: 12-0055

Dear Mr. Ziebell:

This responds to your e-mail regarding identification number (ID) displays on portable tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your follow-up e-mail, you stated that the regulations do not appear to address transport vehicle or container marking requirements when they contain bulk packagings marked in accordance with § 172.336(d). Specifically, you ask for clarification of the marking requirements for a portable tank that is labeled and marked in accordance with § 172.514(c) and § 172.336(d).

The exceptions in § 172.336(d) and § 172.514(c) provide no relief from marking the transport vehicle. The transport vehicle must be marked in accordance with § 172.326(c) if the ID number markings required by § 172.302(a) are not visible. If you choose to use the package marking and labeling exceptions in § 172.336(d) and § 172.514(c), the transport vehicle must be marked in accordance with § 172.302(a).

I hope this information is helpful.



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

172.336, 172.514, 172.326

Regulation Sections

Section Subject
172.326 Portable tanks
172.336 Identification numbers; special provisions
172.514 Bulk packagings