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Interpretation Response #14-0033 ([Canyon State Oil] [Mr. Jason Delto])

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

Interpretation Response Details

Response Publish Date:

Company Name: Canyon State Oil

Individual Name: Mr. Jason Delto

Location State: AZ Country: US

View the Interpretation Document

Response text:

July 30, 2014

Jason Delto
EHS&S Manager
Canyon State Oil
2640 N 31st. St.
Phoenix, AZ 85009

Reference No. 14-0033

Dear Mr. Delto:

This is in response to your February 19, 2014 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the proper certification date for the pressure testing of portable tanks. Specifically, you ask if a 330 gallon portable tank without a current certification date for pressure testing under §180.605(k) can be used to ship a non-hazardous material?

The answer is no. Under § 171.2(g), no person may represent or offer a packaging as meeting the requirements of the HMR unless the packaging is maintained, marked, and retested in accordance with the applicable requirements of the HMR when transported in commerce. These requirements are applicable whether or not the packaging is used for the transportation of a hazardous material. Therefore, if the UN standard or DOT specification packaging used at your facility is not maintained in accordance with the HMR, we recommend you securely cover any identifying marks or specification plates representing it as such.

I hope this satisfies your request.


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

180.605(k), 171.2(g)

Regulation Sections

Section Subject
171.2 General requirements
180.605 Requirements for periodic testing, inspection and repair of portable tanks