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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 #17-0091

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

Interpretation Response Details

Response Publish Date:

Company Name: STE

Individual Name: Anthony Wurl

Location State: WI Country: US

View the Interpretation Document

Response text:

Anthony Wurl
Director of Engineering
STE
801 4th Street
Beloit, WI 53511

Reference No. 17-0091

Dear Mr. Wurl:

This letter is in response to your August 22, 2017, email and subsequent phone calls requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the American Society of Mechanical Engineers (ASME) nameplate marking requirements in § 178.345-14 for a Department of Transportation (DOT) 406, DOT 407, or DOT 412 specification cargo tank. You include in your email photographs of three plates on a cargo tank, each with a different set of markings:

  • The first plate includes the information required in § 178.345-14(c) for a DOT specification plate. 
  • The second plate is located near the first plate and marked with the minimum information required in § 178.345-14(b) for an ASME nameplate.
  • The third plate repeats some, but not all, of the § 178.345-14(b) required markings for an ASME nameplate in a separate location on the cargo tank.  It also shows additional information required in UG-119 of the ASME Code. 

Specifically, you ask whether the HMR require this voluntary, additional ASME nameplate to be in close proximity to the required markings on the other ASME nameplate and the DOT specification plate.

Section 178.345-14(a) requires cargo tanks certified after October 1, 2004, to be marked with a corrosion-resistant metal nameplate (ASME nameplate); and each cargo tank motor vehicle certified after October 1, 2004, must have a specification plate that is permanently attached to the cargo tank by brazing, welding, or other suitable means on the left side near the front in a place accessible for inspection. The information required by the marking requirements is further specified in § 178.345-14(b) and (c). The HMR do not prohibit the use of additional markings or specify a location for their placement.

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

Sincerely,

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

Regulation Sections

Section Subject
178.345-14 Marking