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Interpretation Response #99-0156 ([Manchester Tank] [Mr. John Edmondson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Manchester Tank

Individual Name: Mr. John Edmondson

Location State: TN Country: US

View the Interpretation Document

Response text:

March 17, 2000


Mr. John Edmondson                              Ref. No. 99-0156
Director of Engineering Liaison
Manchester Tank
1749 Mallory Lane, #400
Brentwood, TN 37027

Dear Mr. Edmondson:

This is in response to your letter regarding DOT specification markings on cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if the serial number may be marked on the collar in a sequence other than as specified in § 178.35(f). You provided six drawings depicting serial numbers marked in various locations and asked if these variations are permitted based on § 178.35(f)(1)(iii).

The answer is no.  Section 178.35(f)(1)(iii) authorizes variations in sequence only when necessitated by a lack of space.  In the drawings you provided, the serial numbers appear to be marked out of sequence for a reason other than that allowed.

I trust this satisfies your request.  Please contact us if we can be of further assistance.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
178.35 General requirements for specification cylinders