# Minnesota Department of Transportation Office of Freight and Commercial Vehicle Operations — Hazardous Materials Safety Interpretation **Citation:** 10-0120 **Type / status:** guidance / guidance **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2010-07-12 10-0120 response to Minnesota Department of Transportation Office of Freight and Commercial Vehicle Operations concerning 173.315. ## Document text <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration . 1200 New Jersey Ave, SE Washington, D.C. 20590 JUL 1 2 2010 Mr. Michael Ritchie Minnesota Department of Transportation Office of Freight and Commercial Vehicle Operations 395 John Ireland Blvd. St. Paul, MN 55155-1899 Ref. No. 10-0120 Dear Mr. Ritchie: This responds to your June 4, 2010 letter regarding placarding and marking requirements under the Hazardous MateriaIs.Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask questions regarding the display of markings and placards on a wagon trailer with two nurse tanks mounted side by side (Le., a twin-tank farm trailer). Your letter includes photographs illustrating the twin-tank farm trailers. The capacity of the twin nurse tanks ranges from 1,000 to 1,450 gallons. Your questions are paraphrased and answered as follows: Ql. Are markings and a placard required on the adjacent sides (Le., the interior sides facing each tank) ofthe twin nurse tanks that are not visible from the direction they face? AI. Yes. As a bulk packaging, a nurse tank must be marked and placarded on each side (and each end). See §§ 172.302, 172.328, and 172.504 of the HMR. Q2. If appurtenances (e.g., valves, fittings, etc.) on the end ofa nurse tank prevent markings and a placard from being properly placed and visible on the tank, is that same end ofthe wagon trailer to which the nurse tank is mounted required to be marked and placarded? A2. No. In accordance with § I73.315(m), a nurse tank is not required to be marked and placarded on one end when appurtenances on that end obstruct proper placement and visibility. The provisions of § I73.3I5(m) include securely mounting the nurse tank to a wagon trailer. Thus, it is the opinion ofthis Office that this exception also applies to the end ofthe wagon trailer. Note that with regard to the photographs of the twin-tank farm trailer, the end ofthe <<>> nurse tank with appurtenances is not obstructed sufficiently to prevent proper placement and visibility of markings and a placard. I hope this information is helpfuL If you have further questions, please contact this office. Charles E. Betts Chief, Standards Development ffice of Hazardous Materials Standards <<>> Minnesota Department of Transportation Office of Freight and Commercial Vehicle Operations 395 John Ireland Blvd. 81. Paul, MI\J 55155-1899 June 4, 2010 De( () dere fl ~ 113.315 ~ elZ. 50~ ':3 11 z. ·501· ?IClcarcfJf)j 10- 0 J20 Charles E Betts Chief, Standards Development Office ofHazardous Material Standards USDOTIPHMSA 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Display ofplacards on bulk packagings and transport vehicles. Dear Mr. Betts, Many farm wagon trailers are now transporting two nurse tanks, mounted side by side. These tanks are often separated by only a few inches, and may remain on the farm wagon trailer for several years, until the tanks are removed for maintenance or inspections. Some trailers carry two 1,000 gallon nurse tanks, and some have two 1,450 gallon tanks. These tanks are operated under the provisions of 49 CFR 173.315 (m). I have attached three photographs of twin tank farm trailers. We have received questions from the agricultural chemical industry and Commercial Vehicle Inspectors regarding the required display ofplacards and marking on the adjacent sides ofthe nurse tanks mounted on a two tank trailer. 49 CFR 172.504 requires the display ofplacards on each bulk packaging, unless excepted. Sectionl72.514 requires each person who offers hazardous materials in a bulk package to affix placards specified for that material in §172.504. Section 172.516 requires a placard to be clearly visible from the direction it faces, except from the direction of another transport vehicle or railcar. Question: Are placards and ID number marking required on the adjacent sides oftwo nurse tanks mounted only inches apart on the same farm trailer? The Hazardous Materials Regulations authorize placarding exceptions in §§172.507 (b) and 173.315 (m) (7) is for an end ofa nurse tank ifthat end contains valves, fittings or other appurtenances that prevent placards and marks from being properly placed. Question: If the exceptions authorized in §§ 172.507 (b) and 173.315 (m) (7) are used for a nurse tank with appurtenances on olle end, is it necessary to placard and mark the vehicle (the farm wagon trailer) on that end? An equal opportunity employer <<>> Yours truly, - /;/k~c Cui 1d.;t;;;W Michael Ritchie Hazardous Materials Specialist Minnesota Department of Transportation Commercial Vehicle Operations Section 395 John Ireland Boulevard St. Paul, MN 55155 (651) 366-3697 MichaeLritchie@state.mn.us <<>> AMMONIA 1005 AMMON 100 11 / 308 <<>> AN 005 VINOA PROUS PAHNY IMMOS 1005 US: <<>> 1005 ANHYDROLO AMMONIA 1005 ANHYDROUS AMMONIA ## Provenance - Official: Yes - Source: - Source ID: `phmsa` - SHA-256: `200180147a5c286a0e34cb6785ac6e3cc65ea04f00993d58bf1bf3fe7b3453bb` - Retrieved: 2026-08-20T00:59:31.977Z - Exported: 2026-08-22T06:56:15.850Z - Document slug: `phmsa-interpretation-10-0120` ### Source metadata ```json { "materialSubtype": "interpretation", "interpretationArea": "hazardous_materials", "representation": "full_text_from_official_pdf", "companies": [ "Minnesota Department of Transportation Office of Freight and Commercial Vehicle Operations" ], "individuals": [ "Mr. Michael Ritchie" ], "refIds": [ "10-0120" ], "catalogDates": [ "2010-07-12" ], "catalogParts": [ 173 ], "catalogRowCount": 1, "sourceRecordUrls": [ "https://www.phmsa.dot.gov/node/64231" ], "linkedAttachmentUrls": [], "unavailableResponseUrls": [], "duplicateRepresentationUrls": [], "citedSections": [ "173.315", "172.302", "172.328", "172.504", "172.516", "172.507" ], "catalogPageUrls": [ "https://www.phmsa.dot.gov/regulations/title49/section/173315" ], "pdfUrls": [ "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100120.pdf" ], "representations": [ { "viewUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100120.pdf", "detailUrl": null, "detailHtmlPath": null, "pdfUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100120.pdf", "pdfArtifactPath": "data/sources/phmsa-interpretations/10-0120-acd3126980.pdf", "pdfArtifactSha256": "16ceb269c610d2d82574381dbd01ba1bee8aa460c35dcae96a3cee6245ac4c06", "extractedTextPath": "data/sources/phmsa-interpretations/10-0120-acd3126980.v2.txt", "extractedTextSha256": "bc67eccc7cb3a1fb93ee928aff435586aa344cf42f4feeeb61e6a96ad1893e3c", "pageCount": 7, "extractionVersion": 2 } ], "caveat": "Interpretations apply regulations to the facts presented and do not create independently enforceable requirements.", "jurisdiction": "US" } ```