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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 #21-0029

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

Interpretation Response Details

Response Publish Date:

Company Name: TETRA Technologies

Individual Name: Shawn Shoemake

Location State: TX Country: US

View the Interpretation Document

Response text:

May 4, 2021

Shawn Shoemake
HSEQ Director
TETRA Technologies
24955 Interstate 45N
The Woodlands, TX 77380

Reference No. 21-0029

Dear Mr. Shoemake:

This letter is in response to your March 17, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to bulk packaging requirements for low hazard materials as specified in § 173.241. Specifically, you ask whether you may transport "UN3264, Corrosive liquid, acidic, inorganic, n.o.s, 8, PG III" in a non-specification cargo tank motor vehicle that is suitable for transporting liquids.

The answer is yes. Column (8C) of the Hazardous Materials Table (HMT; § 172.101) prescribes requirements for bulk packagings for a given material, subject to limitations, requirements, and additional authorizations of Columns (7) and (8B). The HMT entry for "UN3264, Corrosive liquid, acidic, inorganic, n.o.s, 8, PG III," lists § 173.241 in Column (8C), which authorizes bulk packagings for certain low hazard liquid and solid materials. In addition to various DOT specification cargo tank motor vehicles, § 173.241(b) also permits the use of non-DOT specification cargo tank motor vehicles suitable for the transport of liquids. Please note that although a non-DOT specification cargo tank motor vehicle is authorized, it is your responsibility to determine whether it is compatible with the lading per § 173.24(e).

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


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

172.101, 173.24(e), 173.241, 173.241(b)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.24 General requirements for packagings and packages
173.241 Bulk packagings for certain low hazard liquid and solid materials