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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 #18-0109

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Jeffrey Cline

Location State: AL Country: US

View the Interpretation Document

Response text:

March 12, 2019

Jeffrey Cline
Director of Strategic Accounts
9216 Autumn Court
Mobile, AL  36695

Reference No. 18-0109

Dear Mr. Cline:

This letter is in response to your July 17, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to non-DOT specification portable tanks.  You state your company wants to construct and transport a roll-off/roll-on portable tank conforming to Special Provision T3 filled with “UN3190, Self-heating solid, inorganic, n.o.s., 4.2, PG II.”  You further explain that while the hazardous material will contain some moisture, there will be no free-flowing liquid.  Specifically, you ask if any additional requirements would apply to a non-DOT specification packaging containing “UN3190” if the portable tank is built with the proper compatibility, closures, venting, and conforms to the requirements of § 173.241.

The answer is yes.  Use of the packaging is also subject to the requirements of Subparts A and B of Part 173, which include general packaging requirements in § 173.24, additional general requirements for bulk packagings in § 173.24b, and any applicable requirements for the use of a portable tank in § 173.32.

You are free to voluntarily construct your non-DOT specification portable tank to the standards in Special Provision T3.  While such a portable tank would be an authorized packaging for the material in accordance with § 173.241, it cannot be represented as a DOT specification packaging or as complying with any DOT standard or requirement.

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

173.241, 173.24, 173.24b, 173.32

Regulation Sections

Section Subject
173.24 General requirements for packagings and packages
173.241 Bulk packagings for certain low hazard liquid and solid materials
173.32 Requirements for the use of portable tanks