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

Interpretation Response #12-0254 ([Poly-Coat Systems, Inc.] [Ms. Suzanne Felix])

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

Interpretation Response Details

Response Publish Date:

Company Name: Poly-Coat Systems, Inc.

Individual Name: Ms. Suzanne Felix

Location State: TX Country: US

View the Interpretation Document

Response text:

February 28, 2013



Ms. Suzanne Felix
Corporate Secretary
Poly-Coat Systems, Inc.
501 Liverpool Spur
Liverpool, TX  77577
Ref. No.: 12-0254

Dear Ms. Felix:

This is in response to your November 08, 2012 email requesting clarification of the requirements for application of the "L" decal on non-DOT specification glass fiber reinforced plastic (GFRP) DOT-407 and 412 equivalent special permit tankers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask if an "L" marking should be applied to non-DOT specification GFRP DOT-407 and 412 equivalent tankers operating under special permit.

Your email does not reference any specific special permits.  However, the lining inspection requirements of § 180.407(f) do not apply if cargo tanks are authorized by the special permit they are operating under to be manufactured and utilized in transportation without a liner. 

Test and inspection marking requirements for cargo tanks are provided in § 180.415.  Section 180.415(a) requires each cargo tank successfully completing the test and inspection requirements contained in § 180.407 to be marked as specified in the rest of that section; to include an "L" marking for lining inspections.  If no liner is present in a cargo tank operating under a special permit, no lining inspection is required and no marking in accordance with § 180.415 is required. 

Unless otherwise provided for by special permit, any cargo tank utilizing a liner is subject to the lining inspection requirements of § 180.407(f) and subsequently the marking requirements in § 180.415(b).   

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

180.407, 180.415

Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks
180.415 Test and inspection markings