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Interpretation Response #15-0229 ([Idaho State Police] [Mr. Thomas Wright])

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

Interpretation Response Details

Response Publish Date:

Company Name: Idaho State Police

Individual Name: Mr. Thomas Wright

Location State: ID Country: US

View the Interpretation Document

Response text:

June 6, 2016

Mr. Thomas Wright
Idaho State Police
5205 S. 5th St.
Pocatello, ID 83204

Ref. No.: 15-0229

Dear Mr. Wright,

This responds to your November 19, 2015 email requesting clarification on shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask if the term “1CTMV” may be used on a shipping paper to satisfy indication of the total quantity of hazardous materials and the number and type of packages as required by §§ 172.202(a)(5) and (a)(7) respectively.  In the scenario described, two cargo tanks are attached to a motor vehicle.
The answer is no.  The term “1CTMV” would not satisfy either the requirement in §§ 172.202(a)(5) or (a)(7).  As defined in § 171.8, a “cargo tank motor vehicle” means a motor vehicle with one or more cargo tanks permanently attached to or forming an integral part of the motor vehicle.  A cargo tank motor vehicle is not considered a package; however, a “cargo tank” means a bulk packaging that is permanently attached to or forms a part of a motor vehicle or is not permanently attached to a motor vehicle but which, by reason of its size, construction or attachment to a motor vehicle is loaded or unloaded without being removed from the motor vehicle.   Under § 172.202(a)(5)(iii)(A), the HMR allow the total quantity of hazmat transported in a bulk package, such as in your scenario, to be described on the shipping paper by indicating the number and type of bulk package(s) (e.g., 2 cargo tanks), rather than an applicable unit of measurement (e.g., gallons, liters).  The term “2 cargo tanks” would also satisfy the § 172.202(a)(7) requirement.
I hope this answers your inquiry.  If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.


Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.202(a)(5) and (a)(7), 171.8, 172.202(a)(5)(iii)(A)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.202 Description of hazardous material on shipping papers
172.202 Description of hazardous material on shipping papers