# Commercial Vehicle Safety Alliance — Hazardous Materials Safety Interpretation

**Citation:** 18-0154  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2019-08-07

18-0154 response to Commercial Vehicle Safety Alliance concerning 172.101, 172.102, 180.407.

## Document text

<<<PAGE 1>>>

0
U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
AUG O rl 20\9
Collin B. Mooney, MPA, CAE
Executive Director
Commercial Vehicle Safety Alliance
6303 Ivy Lane, Suite 310
Greenbelt, MD 20770-6319
Reference No. 18-0154
Dear Mr. Mooney,
This letter is in response to your December 4, 2018, emails and letter requesting clarification of
the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the
requalification testing of cargo tanks. Specifically, you ask four questions concerning the 10-
year internal visual inspection and the 10-year pressure test required for MC 331 cargo tanks in
dedicated propane service prescribed in§ 180.407(c).
We have paraphrased and answered your questions as follows:
Q 1. You ask whether the 10-year internal visual inspection and pressure retest intervals in the
§ 180.407( c) Table only apply to MC 331 bobtail tank trucks (i.e., the cargo tank is
permanently mounted on a truck chassis), with a capacity less than 3,500 gallons in
dedicated propane service, or if they also apply to MC 331 cargo tanks mounted on
trailers.
Al. The 10-year retest exception in§ 180.407(c) applies to all MC 331 cargo tanks of3,500
gallons or less, constructed of the specified non-quenched and tempered (NQT) steel(s),
and used in dedicated propane service. In addition, the 10-year retest requirement applies
to all MC 331 cargo tanks meeting the exception whether the cargo tank is permanently
mounted on a truck chassis, trailer, or other structure.
Q2. You ask whether a motor carrier may fill a cargo tank with "UNI 978, Propane, 2.1
(flammable gas)" and use the exception provided in § 172.102( c )(1 ), Special Provision
19, to qualify the cargo tank for the 10-year pressure retest and internal visual inspection.
A2. Provided the cargo tank is in dedicated propane service, the answer is yes. Special
Provision 19 permits the identification number "UNI 075" to be used in place of the
identification number specified for the hazardous material in column 4 of the § 172.101
Hazardous Materials Table (HMT) (e.g., "1978"}. Further, when one proper shipping
name entry in column 2 of the HMT references another entry by use of the word "see,"

<<<PAGE 2>>>

Q3. A3. Q4. A4. any entry in Roman type that follows may be used as the proper shipping name for that
hazardous material ( e.g., Propane, see Petroleum gases, liquefied or Liquefied petroleum
gas). Thus, propane may be described as "UN1978, Propane," "UN1075, Propane,"
"UN1075, Petroleum gases, liquefied," or "UN1075, Liquefied petroleum gas."
Please note the 10-year pressure retest exception does not apply to other gases with
Special Provision 19 assigned to them in column 7 of the HMT (e.g., Butane or
Propylene). Special Provision 19 requires that the identification number "1075" be used
consistently in all places the identification number appears (e.g., shipping papers,
package marking, and/or emergency response information).
You ask whether the product must be 100 percent propane, or if it can be described as
propane and be a mix of propane and other liquefied petroleum gases if propane is the
primary gas in the mixture and the material is shipped as propane, consistent with
industry standards.
The propane transported does not need to be 100 percent pure propane to meet the
requirements of the 10-year retest exception. The propane may be in a gas mixture
provided the proper shipping name is "Propane" when not using one of the alternate
proper shipping names or identification number permitted under Special Provision 19.
You ask whether carriers must keep a copy of the full-size equivalent (FSE) Charpy V-
notch (CVN) energy test data required for cargo tanks in dedicated propane service, made
of the required NQT steel(s), in the vehicle to take advantage of the 10-year retest in
§ 180.407(c).
The answer is no; the HMR do not require carriers to maintain a copy of the test data on
the transport vehicle. The HMR do not specify, or limit, the location( s) where such test
data may be kept. However, in accordance with§ 180.417(b)(3) of the HMR, each
owner of a cargo tank and, except for a motor carrier who leases a cargo tank for less
than 30 days, each motor carrier who uses a cargo tank must retain copies of the test data
to be eligible for the IO-year retest in§ 180.407(c). In other words, if the cargo tank
owner and motor carrier, when the cargo tank is leased for 30 days or more, does not
retain a copy of the test report, the cargo tank must be retested every 5 years in
accordance with§ 180.407(c).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
~~~V>~
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

<<<PAGE 3>>>

i::. -<-Li JttD~O.rL
Dodd, Alice (PHMSA) From: DerKinderen, Dirk (PHMSA)
Sent: To: Subject:
Attachments:
Tuesday, December 04, 2018 11:53 AM
January, Ikeya CTR (PHMSA); Dodd, Alice (PHMSA)
FW: PHMSA 10-Year Test and Inspection Interpretation Request
PHMSA 10-Year Test and Inspection Interpretation Request.pdf
/ f-0 /51/
Please enter into the interp database and assign.
From: collinm cvsa.org
Sent: Tuesday, December 04, 2018 11:10 AM
To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>; Kelley, Shane (PHMSA) <shane.kelley@dot.gov>
Cc: Mitchell, Aaron (PHMSA) <aaron.mitchell@dot.gov>; DerKinderen, Dirk (PHMSA) <Dirk.DerKinderen@dot.gov>;
adrienneg cvsa.org <adrienneg@cvsa.org>
Subject: PHMSA 10-Year Test and Inspection Interpretation Request
Sorry folks, resending with corrected emails and with the attached interpretation request.
Thank you.
Collin
Direct: 301-830-6149
Main: 301-830-6143
Mobile: 703-407-3223
From: Collin Mooney
Sent: Tuesday, December 4, 2018 11:07 AM
To: infocntr@dot.gov; shane.kelley@dot.gov
Cc: aaron.mitchell@dot.gov; Dirk.DerKinderen@dot.gov; Adrienne Gildea <adrienneg@cvsa.org>
Subject: PHMSA 10-Year Test and Inspection Interpretation Request
Good morning everyone,
The Commercial Vehicle Safety Alliance {CVSA) requests an interpretation pertaining to the 10-year Internal Visual
Inspection and the 10-year Pressure Test on MC331 cargo tanks in dedicated propane service. The attached letter
outlines our request, which includes a PDF of a PowerPoint presentation in order to provide some additional background
information on this issue.
CVSA works to closely monitor, evaluate and identify potentially unsafe transportation processes and procedures as well
as to help facilitate and implement best practices for enhancing safety on our highways. Commercial motor vehicle
safety continues to be a challenge and we need the involvement of all affected parties to help us better understand
these issues and put into place practical solutions. We appreciate the agency's commitment to safety and stakeholder
involvement.
Thank you.
Collin B. Mooney, MPA, CAE
Executive Director
Commercial Vehicle Safety Alliance
1

<<<PAGE 4>>>

6303 Ivy Lane, Suite 310
Greenbelt, MD 20770-6319
Direct: 301-830-6149
Main: 301-830-6143
Mobile: 703-407-3223
collinm@cvsa .org
www.cvsa.org
2

<<<PAGE 5>>>

Commercial Vehicle Safety Alliance
Improving uniformity in commercial motor vehicle safety and enforcement
l ♦ I•
December 4, 2018
Shane Kelley
Director
Standards and Rulemaking (PHH-10)
Pipeline and Hazardous Materials Safety Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
Dear Mr. Kelley,
The Commercial Vehicle Safety Alliance (CVSA) requests an interpretation on the four questions listed below
pertaining to the 10-year Internal Visual Inspection and the 10-year Pressure Test on MC331 cargo tanks in
dedicated propane service. The issue was discussed at the recently completed CVSA 2018 Annual Conference
and Exhibition in Kansas City, Missouri.
CVSA is a nonprofit association comprised of local, state, provincial, territorial and federal commercial motor
vehicle safety officials and industry representatives. The Alliance aims to achieve uniformity, compatibility and
reciprocity of commercial motor vehicle inspections and enforcement by certified inspectors dedicated to driver
and vehicle safety. Our mission is to improve commercial motor vehicle safety and uniformity throughout
Canada, Mexico and the United States, by providing guidance and education to enforcement, industry and policy
makers.
On June 2, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published the HM-218H
Final Rule. One of the rule changes allowed certain cargo tanks, made of NQT steel that were less than 3500
gallons, to extend the internal visual inspection and pressure test intervals to 10 years. Later, on June 18, 2018,
PHMSA published a correction and amendment to the HM-218H Final Rule, clarifying and amending some of the
regulatory language applicable to the 10-year internal visual inspection and pressure test. This rulemaking was
the result of a petition for rulemaking from the National Propane Gas Association (NPGA). The NPGA petition was
the result of a study completed by Battelle on behalf of NPGA.
After reviewing the NPGA petition, Battelle study, HM-215H final rule and HM-215H correction and amendment
document, the CVSA Hazardous Materials Committee determined that the following questions must be
addressed, so this rule can be enforced and complied with in a consistent manner.
6303 Ivy Lane, Suite 310 Greenbelt, Maryland 20770 301-830-6143 www.cvsa.org

<<<PAGE 6>>>

1) The regulations only refer to cargo tanks. Is the intent for this to apply only to bobtails or can it also apply
to trailers?
2) Can a motor carrier load a cargo tank with propane and use special provision 19, which would allow the
proper shipping name to be Petroleum Gases Liquified or Liquified Petroleum Gas and still qualify for the
10-year pressure test and internal visual inspection?
3) Does the product have to be 100 percent propane, or can it be classed as propane and be a mix of
propane and other liquified petroleum gases if propane is the primary gas in the mixture and the material
is shipped as propane, consistent with the industry standard?
4) Are carriers required to keep a copy in the vehicle of the full-size equivalent (FSE) Charpy V-notch (CVN)
energy test data required for cargo tanks in dedicated propane service made of NQT SA-202 and NQT SA-
455 steel, per Note 5 in § 180.407?
The attached pdf document is from a PowerPoint presentation given to our Hazardous Materials Committee at
our 2018 Annual Conference and Exhibition in Kansas City, Missouri. This information provides some additional
background information on this issue.
CVSA works to closely monitor, evaluate and identify potentially unsafe transportation processes and procedures
as well as to help facilitate and implement best practices for enhancing safety on our highways. Commercial
motor vehicle safety continues to be a challenge and we need the involvement of all affected parties to help us
better understand these issues and put into place practical solutions. We appreciate the agency's commitment
to safety and stakeholder involvement.
If you have further questions or comments, please do not hesitate to contact me by phone at 301-830-6149 or
by email at collinm@cvsa.org.
Respectfully,
Collin B. Mooney, MPA, CAE
Executive Director
Commercial Vehicle Safety Alliance
Cc: Aaron Mitchell
Dirk DerKinderen
2
6303 Ivy Lane, Suite 310
Greenbelt, Maryland 20770 301-830-6143 www.cvsa.org

<<<PAGE 7>>>

MC-331 Cargo
Tanks
10 year internal Visual Inspection
and Pressure dest
4201 Commercal Vehicle Satiny Misco Alight pair

<<<PAGE 8>>>

Background
HM-218H published 6/2/16
• Contained provisions for 10 year internal visual
inspection and pressure test on certain cargo tanks in
dedicated propane service.
HM-218H Corrections and Amendments published
on 6/18/18
• Clarified the 10 year test and inspections by correcting
and amending some of the regulatory language.

<<<PAGE 9>>>

Background
• In 2001, NPGA conducted a survey on whether any
failures occurred on tanks with 5 year pressure test.
None on tanks< 3500 gallons water capacity (bobtails).
• NPGA retained Battelle to do a study on the concept of
extending the inspection period of cargo tanks with the
following limitations:
• constructed to specification MC 330 or MC 331
• constructed with non-quenched and tempered steel
• with a capacity of less than 3500 gallons
• in dedicated propane service

<<<PAGE 10>>>

Background
• Battelle conducted a two phase study.
• Battelle published the final report in September 2011.
• The study supported making changes to regulations
with specific parameters.

<<<PAGE 11>>>

Background
Battelle recommended changing the regulations with the
following parameters.
• In dedicated propane service
• Sized less than 3500 gallons water capacity
• Meeting DOT MC-331 specifications
• Constructed of one or more of the following materials:
• Non-quenched and tempered (NQT) SA-612 steel
• Non-quenched and tempered (NQT) SA-202 or SA-455 steels,
provided the materials have full-size equivalent (FSE) Charpy-vee
notch (CVN) energy test data that demonstrate 75% shear-area
ductility at 32F with an average of three or more samples greater
than 15 ft-lb FSE, with none less than 10 ft-lb FSE.

<<<PAGE 12>>>

Background
On January 3, 2012, NPGA petitioned PHMSA
to make changes to the regulations.
• Bobtails making propane deliveries to the end
user.
• Not highway transports, which make deliveries
to bulk facilities.
• Mentions no trailers.
• Makes the same recommendations to PHMSA as
the final Battelle report.

<<<PAGE 13>>>

Background
NPGA petition letter recommendations.
• This study supports NPGA's recommendation to extend the
requalification period from 5 years to 10 years for MC-331
specification cargo tanks that meet the following requirements:
• Used in dedicated propane service;
• Have a water capacity less than 3,500 gallons; and
• Constructed of one or more of the following materials:
• Non-quenched and tempered (NQT} SA-612 steel;
• Non-quenched and tempered (NQT} SA-202 or SA-455 steels, provided the
materials have full-size equivalent (FSE) Charpy-vee notch (CVN} energy test data
that demonstrate 75% shear-area ductility at 32 degrees F with an average of three
or more samples greater than 15 ft-lb FSE, with none less than 10 ft-lb FSE.

<<<PAGE 14>>>

Background
Final Rule language
• The NPGA submitted a petition (P-1604)
requesting that PHMSA modify the pressure
test and visual inspection test requirements
applicable to certain MC 331 specification
cargo tanks in dedicated propane delivery
service, commonly known as bobtails, found
in § 180.407(c).

<<<PAGE 15>>>

Background
Final Rule language continued
• Based on the results of this study, the NPGA and Battelle
recommend that PHMSA modify the requalification period
from five years to ten years for MC 331 cargo tanks that: (1) Are
used in dedicated ro ane service; (2) have a water capacity
less than ,5 ga ons; an are constructed of non-
quenched and tempered (NQT) SA-612 steel and NQT SA-202
or SA-455 steels, provided the materials have full-size
equivalent (FSE) Charpy Vee notch energy test data that
demonstrates 75 percent shear-area ductility at 32 03 with an
average of three (3) or more samples greater than 15 ft-lb FSE
none with less than 10 ft-lb FSE.

<<<PAGE 16>>>

Final rule corrected language in §180.407
COMPLIANCE DATES-INSPECTIONS AND T EST UNDER§ 180.407(c)
Test or inspeclion
(cargo tank specification, configuration. and service)
Date by which first test
must be completed
(see Nole 1)
Interval
period
after first test
External Visual Inspection:
AU cargo tanks designed to be loaded by vacuum with full opening rear heads ..
All other cargo tanks .
lnt&mal Visual Inspection:
All Insulated cargo tanks. except MC 330, MC 331 , MC 338 (see Nole 4) ..
All cargo tanks transporting lading corrosive to the tank .
MC 331 cargo tanks Jess th.an 3,500 gallons water capacity in dedicated propane service con-
structed of nonquenched and tempered NOT SA-612 steel (see Note 5).
All other cargo tanks, except MC 338
Lining Inspection:
All lined cargo tanks transporting lading corrosive to lhe tank .
Leakage Test:
MC 330 and MC 331 cargo tanks In chlorine wrvlce .
All other cargo tanks except MC 338 ..
Pressure Test:
(Hydrostatic or pneumatic) (See Notes 2 and 3) . .. .. ... .. . .. . ....... ....... ........ .... . ............... .
All cargo tanks which are insulated with no manhole or insulated and lined, except MC 338
All cargo tanks design9d to be lr.>aded by vacuum with lull opening £ear heads .
MC 330 and MC 331 cargo tanks In chlorine service .
MC 331 c.argo tanks less than 3.500 gallons water capacity In dedicated propane service con-
structed of nonquenched and lempere<I NOT SA-612 steel {See Note 5).
All other cargo tanks .
Thickness Test:
All unlined cargo tanks transporting material corrosive to the tank, except MC 338 .
September 1 , 1991 . .
September 1 , 1991 .
September 1, 1991 .
September 1, 1991 .
September 1, 1995 ...........
September 1, 1991 .
September 1 , 1991 . .
September 1 . 1991 .
6 months
1 year.
1 year.
1 year.
10 years
5 years
1 year.
2 years.
1 year.
September 1, 1991 .. .
September 1, 1992 .
September 1, 1992 .
September 1, 1995 ....
September 1, 1992 .
1 year.
2 years.
2 years.
10 years.
5 years.
2 years.
MC 331 cargo tanks

<<<PAGE 17>>>

Final rule corrected language in §180.407
COMPLIANCE DATES-INSPECTIONS AND T EST UNDER§ 18O.4O7(c)
Test or inspection
(cargo tank spaclficalion, configuration. and service}
Date by which llrst test
must be complete<:t
(see Nole 1)
Interval
period
after first test
External Visual Inspection:
AH cargo 1anKs designed to be loaded by vacuum with full opening rear heads ..... All other cargo tanks September 1, 1991 .
Sapleml>er 1, 1991 .
6 months.
1 ye&r,
Internal Visual Inspection:
All Insulated cargo tanks. except MC 330, MC 331 , MC 338 {see Note 4
All cargo tanks transport1n · ·
MC 331 ca an s ess than 3,500 gallons water capacity in dedicated propane service con·
structed ol nonquenched and tempered NOT SA-612 steel (see Note 5).
AH other cargo tanks, except MC 338
Lining Inspection:
AU lined cargo tanks transporting lading corrosive to lhe tank .
Leakage Test:
MC 330 and MC 331 cargo tanks In chlorine service
All other cargo 1anks except MC 338 ..
Pressure Test:
(Hydrostatic or pneumatic) (See Notes
All cargo tanks which are insul I h no manhole or insulated and lined, except MC 338 .
Al! cargo tanks desi r e loaded by vacuum with lull opening r~ar heads ...... .
MC 330 and cargo tanks in chlorine service .
MC 331 rgo tanks less lhan 3.500 gallons waler capaclly in dedicated propane service con-
1 year
2 years.
2 years.
10 years.
structed of nonquenched and tempered NOT SA-612 steel (See Note 5}.
All other cargo tanks Septemt>e, 1 , 1995 .. .
5 years.
Thickness Test:
AU unlined cargo tanks lransporting material corrosive to the tank, except MC 338 . September 1, 1992 .
2 years.
th:~~ee 1Ja~~ 8 (~r::e~1n!cttr~bj~~~~~~~IT~c:,?!~,i~~~:n~~e~- ~n;i~~~l~~~1r,~; r~gl:1 :~~!u1
~n~~~i~~ ~,
0 f:sT~~- ~2t:?re a;i
compliance date listed In table I, !he earlier date applies.
N ote 2: Pressure lesling is not required for MC 330 or MC 331 cargo tanks In dedicated sodium metal service.
Note 3: Pressure tesling is not required for uninsulated lined cargo tanks, with a design pressure MAWP 15 psig or less. which receive an ex-
ternal visual inspection and lining lnspecttOn al leas! once each year.
wit~o~e 9 t~~~~~f~u~~~f~i{~gn~~~r~!~~,~~~hin~~~~:~s~::~~~e~f
8e
5~i~Fth~~~~~~k. eit he1 nn Internal visual lnspecti<Jn In conjunction
N ote 5: A 10-year inspection inle,val pe1iod also applies to cargo tanks constructed of NQT SA-202 or NOT SA-455 steel prnvided the mate-
~~: ~a;~:u~esa~':e~e;11tJ~~6>F9J"r'J:,~hv~6 ~~1J~~~)tt~~eFfe~est data that demonstrated 75% shear-area ductl!ity at 32 ~F with an aver-
MC 331 cargo tanks
Dedicated propane service

<<<PAGE 18>>>

Language presents issues at the roadside
based on two issues.
1) Bobtails
2) Dedicated propane service

<<<PAGE 19>>>

Special provision 19
For domestic transportation only, the
identification number "UN1075" may be used
in place of the identification number specified
in column (4) of the §172.101 table. The
identification number used must be consistent
on package markings, shipping papers and
emergency response information.

<<<PAGE 20>>>

Special Provision 19 gases
UN 1011 Butane
UN 1012 Butylene
UN 1055 lsobutylene
UN 1969 lsobutane
UN 1978 Propane
UN 1977 Propylene

<<<PAGE 21>>>

Special Provision 19 gases
All six gases or mixtures of the gases
may be shipped as:
UN1075, Petroleum gases liquefied or
UN1075, Liquified petroleum gas

<<<PAGE 22>>>

Currently if a bobtail cargo tank meets the
requirements for the 10 year internal visual
inspection and pressure test the shipping papers,
cargo tank marking and emergency response
information should all refer to Propane regardless
of whether UN 1075 or UN 1978 is used.
• In this case there is no violation.

<<<PAGE 23>>>

The propane industry
Propane delivered to the end user for
residential or business use is normally
not 100% pure.
It's still classified and shipped as
propane because propane is the primary
ingredient.

<<<PAGE 24>>>

Propane used by the end user
Safety Data Sheet Breakdown from seven different manufactures
1· Propane% *Butane% Ethane%
trs~
■" Propane
~,.~;.i:%f-,m!:
■ Propane 0-2.5 0-7
■ Propane
■ Propane 100
■: Propane
■ Propane >=90 <2.5 <6
■ Pro ' pane ij"is <6
*Includes lsobutane
**Includes propene
**Propylene%
-~ 0-10 ~
f
0-10
1, 2, 6 and 7 are typical end
user propane (residential)
3, 4 and 5 are for
industrial use requiring
more purity

<<<PAGE 25>>>

Emergency Response
• Emergency response procedures are the
same for all of the liquified petroleum gases
(LPGs).
• The 2016 DOT Emergency Response
Guidebook sends you to guide 115 for all of
the LPGs.

<<<PAGE 26>>>

This brings us to three questions we need PHMSA to
clarify.
1) The regulations only refer to cargo tanks. Is the intent for this
to apply only to bobtails or can it also apply to trailers?
2) Can I load a cargo tank with propane and use special
provision 19, which would allow the proper shipping name to
be Petroleum gases liquified or Liquified petroleum gas and
still qualify for the 10 year tests and inspections?
3} Does the product have to be 100% propane or can it be
classed as propane and be a mix of propane and other
liquified petroleum gases as long as proeane is the primary
gas in the mixture and the material is shipped as propane?
()"his is the industry standard.)

<<<PAGE 27>>>

We need a recommendation from the
committee to draft a letter requesting an
interpretation on these three issues.
The action item will be taken to the
board and the letter drafted once we get
board approval.

<<<PAGE 28>>>

© 20LH Commercial Ver
ice Safety Alliance All nuts.

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/71956/180154.pdf>
- Source ID: `phmsa`
- SHA-256: `17e71c8f37056a6ee04e343f1db48a316d4c54a07b8db6347e83403b849b0611`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T00:43:48.309Z
- Document slug: `phmsa-interpretation-18-0154`

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