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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 #99-0168 ([HMT Associates, L.L.C.] [Mr. Andy Altemos])

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

Interpretation Response Details

Response Publish Date:

Company Name: HMT Associates, L.L.C.

Individual Name: Mr. Andy Altemos

Location State: DC Country: US

View the Interpretation Document

Response text:

JUL 12, 1999


Mr. Andy Altemos                           Ref. No. 99-0168
HMT Associates, L.L.C.
1850 K Street, N.W., Suite 200
Washington, DC 20006

Dear Mr. Altemos:

This is in response to your June 15, 1999 request concerning the location of the name plate and requalification markings on a DOT 51 portable tank.

The portable tank in question is in an upright position on its ends and is enclosed by a square metal configuration.  Access to the tank valves, the ASME and DOT specification plates, and the requalification markings is achieved by lifting a hinged top cover.  You submitted drawings of a portable tank for our review and asked if the location meets the requirements of the regulations.

The answer is no.  Section 178.245-6 requires the name plate with the required markings to be in close proximity to the ASME  Full stamp certification.  Paragraph UG-116(j) of the ASME Code states that the markings must be in a conspicuous place on the vessel, preferably near a manhole or handhole.  With regard to the periodic retest marking, § 173.32(e)(3) of 49^CFR requires the date of the most recent periodic retest to be marked on the tank, on or near the metal certification plate, in accordance with § 178.3. Section 178.3(a)(1) states that the specification marking must be in an unobstructed area.  Markings that are obscured from view by a cover do not satisfy the requirement for an unobstructed area.

I hope this satisfies your request.  Should you have any further questions, please contact this office.



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


Regulation Sections

Section Subject
173.32 Requirements for the use of portable tanks