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 |