# Hazardous Materials Division, Federal Motor Carrier Safety Administration — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 02-0029
- **title:** Hazardous Materials Division, Federal Motor Carrier Safety Administration — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2002-05-21
- **effective on:** Not available
- **summary:** 02-0029 response to Hazardous Materials Division, Federal Motor Carrier Safety Administration concerning 173.315.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0029.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0029.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0029
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020029.pdf
**body:**

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....
Memorandum
U.S. Department
of Transportation
Research and
Administration
Special Programs
Date:
MAY 2 1 2002
Reply to Attn. of: Ref. No. 02-0029
Subject: Response to Request for Interpretation
•
Delmer Billings
for finer wher
Chief, Standards Development
Office of Hazardous Materials Standards
To: William Quade
Chief of Hazardous Materials Division
Federal Motor Carrier Safety Administration
This responds to your request for clarification, by memo dated January 25, 2002, related to the
marking and placarding requirements applicable to the transportation of propane in storage tanks under
the Hazardous Materials Regulations (HMR;49 CFR Parts 171 -1 80). Specifically, you requested our
office to review your draft of interpretation and clarify any issues, if applicable.
Note, your letter of clarification has been reviewed and revised as follows:
Q1. What is the marking requirements for a propane storage tank meeting the definition of a bulk
package that is transported by highway in accordance with the provisions of 49 CFR 173.315()?
A1. Under the requirements in 49 CFR §172.302 and §172.331, a storage tank that is a bulk
packaging must be marked with the identification number. If the tank capacity is greater than 1000
gallons, the tank must be marked on each side and each end. If the tank capacity is less than 1000
gallons, the tank need only be marked on two opposing sides. In addition, § 172.331 requires the
transport vehicle to be marked if the identification number is not visible.
Q1. What is the placarding requirements for a propane storage tank meeting the definition of a bulk
package that is transported by highway in accordance with the provisions of 49 CFR 173.315(j)?
Al. Under the requirements in 49 CFR §172.504 and §172.514, a bulk package containing any
quantity of HM must be placarded on each side and each end. If the placards are not visible, the
transport vehicle must also be placarded. Section 172.514 also permits a bulk storage tank with a

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volumetric capacity of less than 18 cubic meters (640 cubic feet) to be placarded on two sides, or
alternatively, labeled in accordance with subpart E of 49 CFR Part 172. In all cases, however, the
transport vehicle must have placards that are visible on all four sides.
I trust this satisfies your inquiry. If this Office can be of further assistance, please contact us.
#

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Webb
•
U.S. Department
Memorandum
Of Transportation
Federal Motor Carrier
$|73.315
Safety Administration
Midwest Service Center
Cargo Fanks
Subject: Request for Interpretation
Date: 022-9002
00L4
Marking & Placarding Requirements
for Propane Storage Tanks
From:
Joe DeLorenzo
HazMat Specialist
In Reply Refer To:
MC-EFM-SV
To:
Bill Quade
Chief, HazMat Division
Attached is a request for interpretation, with a proposed answer regarding the marking and
placarding requirements for a propane storage tanks transported in accordance with 49 CFR
173.315(). Also attached are several interpretations that were reviewed in developing this
request. In some cases these interpretations conflict with one another or do not provide a
comprehensive answer to the general question, and this was the primary reason for developing
provided for at the leo han hamn pounds ain, it sars the a cardie eepion basis inv
these issues.
the regulations for this as these are bulk packages. The attached interpretation would clarify
Please feel free to contact me if you need any additional information.
correct for ture period ie 1987
cc: Danny Shelton
Attachments)
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- **body characters:** 3559