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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 #17-0136

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

Interpretation Response Details

Response Publish Date:

Company Name: HSSE Consulting Services Inc./NATC Inc.

Individual Name: Len Comtois

Location State: QC Country: CA

View the Interpretation Document

Response text:

June 22, 2018

Mr. Len Comtois
HSSE Consulting Services Inc./NATC Inc.
2830 Rue du Trotteur
St-Lazare, Quebec J7T3M2

Reference No. 17-0136

Dear Mr. Comtois

This letter is in response to your December 13, 2017, email and subsequent phone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Transport Canada specification glass-fibre reinforced plastic (GFRP) cargo tanks. Specifically, you ask if GFRP cargo tanks manufactured in Canada and certified to MC 312/TC 312 and/or TC 412 specification may be loaded in Canada for delivery into the United States and reloaded in the United States for delivery into Canada.

The answer is no. Under the provisions of § 171.12(a)(3), a cargo tank motor vehicle authorized by the Transport of Dangerous Goods (TDG) Regulations may be used when it is equivalent to a corresponding Department of Transportation (DOT) specification authorized by the HMR. The HMR does not authorize GFRP cargo tanks. Therefore, GFRP cargo tanks cannot be transported and reloaded in the United States unless approved under the terms of a special permit.

You may apply to PHMSA for a special permit by submitting an application to the Associate Administrator for Hazardous Materials Safety in conformance with the requirements prescribed in 49 CFR Part 107, Subpart B.  In your application, you must provide justification that the packaging design you are considering achieves a level of safety that is equal to or greater than that required under the HMR. You may obtain information on the special permit application process from our website at: or by calling PHMSA's Approvals and Permits Division at (202) 366-4511.

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


Duane Pfund
International Program Coordinator

Regulation Sections

Section Subject
171.12 North American Shipments