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Interpretation Response #98-0418 ([Air Products and Chemicals, Inc.] [Mr. Richard J. Lloyd])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air Products and Chemicals, Inc.

Individual Name: Mr. Richard J. Lloyd

Location State: PA Country: US

View the Interpretation Document

Response text:

APR 17, 1998

Mr. Richard J. Lloyd
Air Products and Chemicals, Inc.
7201 Hamilton Boulevard
Allentown, PA 18195-1501

Dear Mr. Lloyd:

This is in response to your letter of March 6, 1998, requesting clarification of marking requirements for portable tanks in § 172.326(b) of the Hazardous Materials Regulations (HMR.; 49 CFR Parts 171-180). You question whether the marking of the owner's name on a leased IM101 portable tank intended for export shipment satisfies § 172.326(b).

The answer is no. The name of the owner or of the lessee, if applicable, must be displayed on a portable tank that contains a hazardous material (§172.326(b)). If a portable tank is leased, the lessee's name must be marked on the tank. A leased tank makes the marking of the lessee's name an applicable requirement.

I hope this answers your inquiry. If you need additional assistance, do not hesitate to contact us.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
172.326 Portable tanks