Interpretation Response #24-0100
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Mann Energy Services
Individual Name: Mitchell Rumple
Location State: ND Country: US
View the Interpretation Document
Response text:
December 20, 2024
Mitchell Rumple
EHS Director
Mann Energy Services
12257 26F St. NW
Watford City, ND 58854
Reference No. 24-0100
Dear Mr. Rumple:
This letter is in response to your October 19, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to markings on cargo tanks. Specifically, you ask whether the "Emergency Shutoff" marking requirement provided in § 172.328(d) permits the use of a hyphen in the word shutoff as follows: "SHUT-OFF". In a follow-up email, you also provided a picture of the scenario you described.
The answer is yes. Although the required text of "Emergency Shutoff" provided in § 172.328(d) does not include a hyphen in the word shutoff, it is the opinion of this Office that inserting a hyphen as described is not contrary to the intent of the requirement and does not cause confusion, alter, or diminish the meaning or effectiveness of the marking.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
172.328(d)
Regulation Sections
| Section | Subject |
|---|---|
| 172.328 | Cargo tanks |