Interpretation Response #24-0001
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Ohio Public Utilities Commission
Individual Name: Tom Forbes
Location State: OH Country: US
View the Interpretation Document
Response text:
April 24, 2024
Tom Forbes
Chief, Motor Carrier Enforcement
Ohio Public Utilities Commission
180 E. Broad Street
Columbus, OH 43215
Reference No. 24-0001
Dear Mr. Forbes:
This letter is in response to your January 4, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the ground clearance for Department of Transportation (DOT) Motor Carrier (MC) 300 series cargo tanks. You ask whether the landing gear and other attachments—under the reserved regulations for DOT MC 300 series cargo tanks (previously § 178.340-8(d)(2))—are considered components and/or protective devices that must maintain the minimum road clearance requirement of 12 inches.
The answer is yes. It is the opinion of this Office that, as it applies to DOT MC 300 series cargo tanks and the road clearance requirements specified in reserved § 178.340-8(d)(2), the landing gear and other attachments described in your email would be considered components of a DOT MC 300 series cargo tank and would require the minimum road clearance of 12 inches.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
178.340-8(d)(2)