Interpretation Response #25-0045
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: MP Environmental Services, Inc.
Individual Name: Mike Reed
Location State: CA Country: US
View the Interpretation Document
Response text:
March 27, 2026
Mike Reed
MP Environmental Services, Inc.
3400 Manor Street
Bakersfield, CA 93308
Reference No. 25-0045
Dear Mr. Reed:
This letter is in response to your April 11, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cargo tank certification plates in reserved § 178.340-10.
We have paraphrased and answered your questions as follows:
Q1. Is it permissible under § 178.340-10 to leave the loading limits section empty or listed as "none" on the cargo tank certification plate?
A1. No. Section 178.340-10(b)(1) requires loading limits be listed on the cargo tank certification plate. Determining the loading limits is part of certification required in 178.340-10(b).
Q2. Is it permissible under § 178.340-10(b)(1) to provide the loading limit requirements in inches of mercury (inHg) instead of gallons per minute (gpm) or pounds per square inch gauge (psig)?
A2. No. The requirements in § 178.340-10(b)(1) specify that the loading limit be expressed in gpm, psig, or both. It is the opinion of this Office that listing the pressure in inches of mercury (Hg) does not meet the intent of § 178.340-10(b)(1).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
178.340-10(b)
Regulation Sections
| Section | Subject |
|---|---|
| 178 | SPECIFICATIONS FOR PACKAGINGS |