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Interpretation Response #99-0003 ([Wright's Trucking & Harvesting] [Mr. Kent C. Wright])

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

Interpretation Response Details

Response Publish Date:

Company Name: Wright's Trucking & Harvesting

Individual Name: Mr. Kent C. Wright

Location State: NE Country: US

View the Interpretation Document

Response text:

APR 13, 1999

Mr. Kent C. Wright                       Ref No. 99-0003
Wright's Trucking & Harvesting
HC.85 Box 163
Bridgeport, NE 69336

Dear Mr. Wright:

This is in response to your letter dated December 24, 1998, requesting clarification on the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to your harvesting operation involving a fuel truck.  Specifically, you are requesting clarification on whether your service truck carrying a bulk fuel tank which powers the truck and is also used for offloading diesel fuel into the harvesting equipment is required to be placarded.

It is the opinion of this office that if a fuel tank meets the requirements for all fuel systems under §§ 393.65 and 393.69 of the Federal Motor Carrier Safety Regulations (FMCSR), including marking, and is maintained in accordance with NFPA/ASME standards for fuel systems, and not used as a packaging for hazardous materials, e.g., a cargo tank, then it is subject only to the FMCSR.  However, if it does not meet the FMCSR requirements for fuel systems, then the fuel tank would meet the definition of a "cargo tank" (see § 171.8). Under the HMR, a cargo tank is subject to specification packaging, shipping papers, marking, placarding, and emergency response information requirements.

I hope this answers your inquiry.



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


Regulation Sections

Section Subject
171.8 Definitions and abbreviations