{"operation":"document","citation":"02-0163","title":"Suburban Propane — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-07-10","effective_on":null,"summary":"02-0163 response to Suburban Propane concerning 178.337.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0163.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0163.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0163","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020163.pdf","body":"<<<PAGE 1>>>\n\n•*•\n\"\nU.S. Department\n•\nof Transportation\n400 Seventh St., S.W.\nResearch and\nJUL 10 2002\nWashington, D.C. 20590\nSpecial Programs\nAdministration\nMr. Michael G. Merrill\nDirector, Safety and Training Services\nRef. No. 02-0163\nSuburban Propane\n240 Route 10 West\nWhippany, NJ 07981-0206\nDear Mr. Merrill:\nThis is in response to your May 29, 2002 letter, requesting concurrence that the addition of your\nwebsite address to your existing company logo on cargo tank motor vehicles, meets the intent of\n§ 178.337-1 (d) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nSpecifically, you state that the black letters of your website address would be located below your\nexisting red stripe and on the lower half of the cargo tank as shown in the enclosed photograph.\nYou indicate that the website address is approximately 0.33 square feet of the total 293 square\nfoot surface area of the cargo tank.\nAs defined in § 178.337-1(d), every uninsulated cargo tank permanently attached to a cargo tank\nmotor vehicle shall, unless covered with a jacket made of aluminum, stainless steel, or other\nbright non-tarnishing metal, be painted a white, aluminum or similar reflecting color on the\n. upper two-thirds of area of the cargo tank.\nIt is the opinion of this Office that the addition of your website address to your existing company\nlogo on the cargo tanks, as shown in the photograph you supplied, does not conflict with\n§ 178.337-1(d); therefore, you appear to be in compliance with that section.\nI hope this information is helpful. If we can be of further assistance, do not hesitate to contact us.\nSincerely,\n-\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\n• \"\nSuburban Propane™\nOne Suburban Plaza • 240 Route 10 West • P.O. Box 206 • Whippany, NJ 07981-0206\nhttp://www.suburbanpropane.com\nOffice 973-887-5300\n9735155986\nFoster\n§178.337-1 (d\nMay 29, 2002\nCargo Tanks\nVia Registered Mail P 349 792 833\nReturn Receipt Requested\n02-0163\nEdward Mazzullo, Director\nHazardous Material Transportation\nDHM 10\nUS Department of Transportation / RSPA\n400 7* Street S.W.\nWashington, DC 20590-0001\nRE: Addition to Company Logo on Cargo Tank Motor Vehicle\nDear Mr. Mazzullo:\nSuburban Propane needs concurrence in writing that the addition of our website address to our\nexisting Company Logo on Cargo Tank Motor Vehicles meets the intent of 178.337-1(d).\nAttached you will find a photograph of our intended addition to our Company logo. The black\nletters will be located below our existing red stripe and on the lower half of the cargo tank.\nSection 178.337-1(d) identifies that a Cargo Tank is painted white, aluminum or similar\nreflecting color on the upper two-thirds of the area of the tank. DOT has traditionally allowed\nthe owner's logo and placarding in that area. The additional area covered by the website address\nlettering is approximately 0.33 square feet of the total 293 square foot surface area of the Cargo\nTank.\nSuburban is intending to include the website address on approximately 1,200-Cargo-Tank-Motor-\nVehicles in our fleet throughout the United States. We request your concurrence prior to\nproceeding with this program.\nYour expeditious review and response will be appreciated. I will be pleased to provide\nadditional information as required.\n•..\nVery truly yours,\nMichael G. Merrill\nDirector--Safety and Training Services\nAttachment\n\n<<<PAGE 3>>>\n\nSuburban Propane\nNOT\nwww.suburbanpropane.com\n-7..\nurban\nPROPANE\n075\npane","truncated":false,"body_characters":3508}