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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 #13-0180 ([Mr. Tom Alexander])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Tom Alexander

Location State: SC Country: US

View the Interpretation Document

Response text:

November 18, 2013

Mr. Tom Alexander
5255 Virginia Avenue
North Charleston, South Carolina 29406-3615

Ref. No.: 13-0180

Dear Mr. Alexander:

This responds to your August 27, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the placarding and marking of cargo tanks containing petroleum distillates.  Specifically, your question pertains to a cargo tank equipped with two compartments.  Compartment #1 contains “UN 1203, Gasoline”; Compartment #2 contains a residue of “NA 1993, Diesel fuel.”  You ask if the cargo tank should display both the “UN 1203” and “NA 1993” identification numbers when in transportation.

Under § 173.29 of the HMR, an empty packaging containing only the residue of a hazardous material shall be offered in transportation and transported in the same manner as when it previously contained a greater quantity of hazardous material.  In addition, under § 172.336(c)(5), identification numbers are not required for each of the different petroleum distillate fuels transported in a cargo tank if the identification number for the petroleum distillate fuel with the lowest flash point is displayed.  Therefore, in your scenario, it would be permitted for the shipper to only display a placard for the petroleum distillate with the lowest flash point.

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.29, 172.336

Regulation Sections

Section Subject
172.336 Identification numbers; special provisions
173.29 Empty packagings