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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #98-0579 ([National Tank Truck Carriers, Inc.] [Mr. John L. Conley])

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

Interpretation Response Details

Response Publish Date:

Company Name: National Tank Truck Carriers, Inc.

Individual Name: Mr. John L. Conley

Location State: VA Country: US

View the Interpretation Document

Response text:

APR 3, 1998


Mr. John L. Conley
Vice President
National Tank Truck Carriers, Inc.
2200 Mill Road
Alexandria, VA 22314-4677

Dear Mr. Conley:

This is in response to your request for clarification of certain requirements for cargo tank motor vehicles in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180). Your questions are paraphrased and answered as follows:

Q1. When a carrier has to perform a periodic test or inspection as required by § 180A07(c), does the carrier have until the last day. of the month or must the next test or inspection be performed based on the exact date as the previous test or inspection?

A1. A carrier has until the last day of the month and year in which the inspection or test is due. For example, if a test or inspection report reflects that an external visual inspection was performed on January 15, 1994, the carrier has until January 31, 1995, to perform the required test or inspection.

Q2. Section 172.328(b) requires that each cargo tank transporting a Class 2 material must be marked on each side and each end with the proper shipping name of ¢.e product being transported, can the proper shipping name be displayed on the cargo tank itself or on a sign bracket installed on the cargo tank?

A2. Either method may be used to display the proper shipping name on the cargo tank.

Q3. In the case of a bobtail tank truck, i.e. the cargo tank is mounted on a truck chassis, can the marking be displayed on the cargo tank itself or on the front of the cab?

A3. Display of the shipping name on the front bumper of the motor vehicle hauling a cargo tank does not satisfy the marking requirement in § 172.328(b). For gases such as "Propane," the shipping name must be marked and displayed in lettering, no less than 50 mm (2.0) inches), on each side and each end of the cargo tank.

Q4. In the case of a tractor semi-trailer combination, can the marking be displayed on the cargo tank itself or on the front of the cab?

A4. See answer A3 above.

I hope this information is helpful and I apologize for the delay in responding. If we can be of further assistance, please contact us.



Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

180.407, 180.417

Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks
180.417 Reporting and record retention requirements