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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 #13-0108 ([Eastex Crude Company] [Ms. Kathy Harris])

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

Interpretation Response Details

Response Publish Date:

Company Name: Eastex Crude Company

Individual Name: Ms. Kathy Harris

Location State: TX Country: US

View the Interpretation Document

Response text:

July 31, 2013


Ms. Kathy Harris
Safety Director
Eastex Crude Company
10907 Ste Hwy 11 W
Leesburg, TX 75451

Ref. No.: 13-0108

Dear Ms. Harris:

This is in response to your letter requesting clarification of certain requirements under the Hazardous Materials Regulations (HMR; 49 CFR Part 171-180) applicable to the highway transportation of “High Gravity Condensate,” in a cargo tank, classified as either “UN1267, Petroleum Crude Oil, Class 3, Packing Group I/II” or “UN1268, Petroleum Products, n.o.s (condensate), Class 3, Packing Group I/II.”  Your questions are paraphrased and answered below:

Q1.  What are the requirements to transport “High Gravity Condensate” in a cargo tank in TX, LA, OK, and NM?

A1. The HMR apply to any person that transports or causes to be transported or shipped hazardous materials in interstate, intrastate, and foreign commerce, by all modes of transportation (i.e., highway, rail, air, and vessel).  The HMR include requirements for packaging, marking, labeling, shipping paper documentation, emergency response information, placarding, and training.

Q2.  What placard is required for “High Gravity Consendate”?

A2.  A cargo tank containing a class 3, packing group I or II material, must display a FLAMMABLE placard as described in § 172.542.  In addition, bulk packagings (e.g., cargo tanks) must display identification numbers on the placard in accordance with § 172.332(c) or on orange panels in accordance with § 172.332(b).

Q3.  What are the driver training requirements to transport “High Gravity Condensate”?  

A3.  The HMR require that the driver must receive hazardous materials training (see §§ 177.800(c) and 177.816). This training must include general awareness, function-specific, safety, and security awareness training as specified in § 172.704(a) of the HMR, as well as driver training in the applicable requirements of Federal Motor Carrier Safety Regulations (FMCSR; 49 CFR parts 390 through 397) and the procedures necessary for the safe operation of that motor vehicle. Training conducted to satisfy compliance with the current Federal Motor Carrier Safety Administration (FMCSA) requirements for a Commercial Driver’s License (CDL) with a tank vehicle or hazardous materials endorsement may be used to satisfy the training requirements set forth in § 172.704 to the extent that such training addresses the training components specified in § 172.704(a).  Where this training does not satisfy the HMR, the employer or self-employed person performing these tasks must provide additional training that satisfies these requirements (see § 177.816(c) and (d)).  In addition, CDLs and hazardous materials endorsements are regulated by FMCSA in accordance with 49 CFR Part 383.  Questions regarding FMCSA regulations should be directed to the appropriate FMCSA field office.  A list of FMCSA field offices and contact information is available at “ /displayfieldroster.aspx,” or you may contact FMCSA at their headquarters offices in Washington, D.C., at (202) 366-6121.

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

172.542, 172.704, 177.800

Regulation Sections

Section Subject
172.542 FLAMMABLE placard
172.704 Training requirements
177.800 Purpose and scope of this part and responsibility for compliance and training