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Interpretation Response #15-0229R ([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:

November 3, 2016

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

Reference No. 15-0229R

Dear Mr. Wright,

This is in reference to PHMSA's response to your request for interpretation Ref. No. 15-0229 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) issued on June 6, 2016. PHMSA received a letter in response to the June 6 interpretation from Professional Emergency Resource Services (PERS) noting a previously issued letter of interpretation issued on September 17, 2008 (Ref. No. 08-0080) with alternate guidance. After further consideration, interpretation letter Ref. No. 15-0229 has been superseded by this revised letter.

In your original request, you asked if the term "1CTMV" representing "one cargo tank motor vehicle" 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. The scenario described two cargo tanks attached to a motor vehicle. In the June 6, 2016 letter, PHMSA stated that the term "1CTMV" would not satisfy either the requirement in §§ 172.202(a)(5) or (a)(7) on the basis that a "CTMV" does not meet the definition of a package.

Based on a review of interpretation letter Ref. No. 08-0080, PHMSA has reconsidered its position in the June 6, 2016 letter. In the September 17, 2008 letter, PHMSA advised that a CTMV consisting of two separate cargo tanks may be described on a shipping paper with the phrase "cargo tank motor vehicle" indicating the type of package. Consistent with the 2016 letter, PHMSA maintains that the term "cargo tank" most appropriately describes the type of package; however, the term "cargo tank motor vehicle" or "CTMV" is acceptable.

If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.



Ben Supko
Senior Regulations Officer
Standards and Rulemaking Division

172.202(a)(5) or (a)(7)


CC:  Mr. Rick Heylmun
      Operations Manager
      Professional Emergency Resource Services
      P.O. Box 1560, Ogden Utah 84402-1560

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers