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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 #22-0051

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

Interpretation Response Details

Response Publish Date:

Company Name: Inliner Solutions

Individual Name: Wayne W. Carver

Location State: IN Country: US

View the Interpretation Document

Response text:

October 25, 2022

Mr. Wayne W. Carver
Inliner Solutions
4520 North State Road 37
Orleans, IN  47452

Reference No. 22-0051

Dear Mr. Caver:

This letter is in response to your May 17, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to fuel systems powering equipment mounted on a motor vehicle. Specifically, you ask whether the tanks fueling your equipment require placarding and therefore require a driver with a hazmat endorsement on his or her Commercial Driver's License.

As defined in § 171.8, a fuel tank is a tank—other than a cargo tank—used to transport flammable or combustible liquid, or compressed gas, for the purpose of supplying fuel for propulsion of the transport vehicle to which it is attached, or for the operation of other equipment on the transport vehicle. Therefore, provided the permanently-mounted tanks: 1) meet the requirements of 49 CFR §§ 393.65 and 393.67 of the Federal Motor Carrier Safety Regulations for liquid fuel systems; 2) are used only for supplying fuel for the operation of the motor vehicle or its auxiliary equipment; and 3) are not marked as Department of Transportation specification cargo tanks nor meet the definition of a cargo tank, as defined in § 171.8, the mounted fuel tanks are not subject to the HMR with respect to their use on the vehicle.

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


Regulation Sections

Section Subject
171.8 Definitions and abbreviations