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Interpretation Response #17-0045 ([SeaFair USA LLC] [Mr. Michael Daum])

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

Interpretation Response Details

Response Publish Date:

Company Name: SeaFair USA LLC

Individual Name: Mr. Michael Daum

Location State: NJ Country: US

View the Interpretation Document

Response text:

July 18, 2017

Michael Daum
Compliance & Quality Manager
1090 King Georges Post Road Suite 403
Edison, NJ 08837

Reference No. 17-0045

Dear Mr. Daum:

This letter is in response to your April 19, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements for the use of portable tanks. Specifically, you ask if a specification portable tank filled with a non-regulated material needs to be filled in accordance with the requirements of § 173.32(f)(5).

The answer is no. A material that is not defined as a “hazardous material” in accordance with the HMR is not subject to the requirements of the HMR, including the requirements for loading of portable tanks in § 173.32(f)(5).

I hope this information is helpful. Please contact us if we can be of further assistance.



Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.32 Requirements for the use of portable tanks