{"operation":"document","citation":"02-0307","title":"Mark Rite Lines Equipment Company, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-12-20","effective_on":null,"summary":"02-0307 response to Mark Rite Lines Equipment Company, Inc. concerning 171.8.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0307.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0307.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0307","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020307.pdf","body":"<<<PAGE 1>>>\n\nDEC 2 0 2002\n400 Seventh St., S.W.\nesearch an\nWashington, D.C. 20590\ndimini ration\nMr. Milo A. Thomas\n5379 Southgate Drive\nMark Rite Lines Equipment Company, Inc.\nRef. No. 02-0307\nBillings, MT 59107-1154\nDear Mr. Thomas:\nThis is in response to your letter dated November 12, 2002, requesting clarification on the\napplicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to your\n\"highway striping vehicle\" with propane tanks permanently mounted to the truck. Specifically,\nyou request clarification of the placarding requirements for your highway striping vehicle that is\nequipped with a large permanently mounted propane tank used to supply fuel to auxiliary\nequipment.\nIt is the opinion of this office that if the propane tank meets the requirements for all fuel systems\nincluding marking, and is maintained in accordance with the National Fire Protection\nunder §$ 393.65 and 393.69 of the Federal Motor Carrier Safety Regulations (FMCSR),\nAssociation's and the American Society of Mechanical Engineers' standards for fuel systems,\nand not used as a packaging for hazardous materials, e.g., a cargo tank, then the tank is subject\nthe tank does not meet the FMCSR requirements for fuel systems, then the fuel tank would\nonly to the FMCSR and as such the vehicle would not be required to be placarded. However, if\ndepending on size meet the definition of a non-bulk or bulk packaging (see § 171.8). Under the\nHMR, propane in a non-bulk or bulk packaging is subject to specification packaging, shipping\npapers, marking, placarding, and emergency response information requirements.\nI hope this information is helpful.\ntitle I. michel\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n171.8\n020307\n\n<<<PAGE 2>>>\n\nBetts\n$171.8\nNAL\nMRL\nDefinitions Placardine\nMark Rite Lines Equipment Company, Inc.'\nMAL AQUEMENT COMPANY, INC.\n5379 Southgate Drive / PO Box 31154\n2 -838÷\nBillings, MI 59101\nPROVIDING QUALITY PRODUCTS\nPhone: (406) 869-9900\nFax: (406) 896-8880\nSINCE\n1989\n12 November, 2002\nChief, Standards Development\nDelmer F. Billings\nOffice of Hazardous Materials Standards\n400 Seventh Street SW\nU.S. Department of Transportation\nWashington, D.C. 20580\nDear Mr. Billings:\nMy situation in question is a large LP tankS permanently attached to the truck that is used to supply fuel to\nThis letter is in response to a recent inquiry concerning the use of place cards on highway striping equipment.\njob sight.this auxiliary equipment is not in use, leaving me to believe the tarks may be considered a cargo\nauxiliary equipment also permanently mounted to the truck. Often when the truck is in transit from job sight.to\ntank.\nWrite dated 13 April, 1999 and a letter sent to Mr. Wayland Little dated 11 January, 1995. It is my\nI have contacted a representative from your department who sent me a copy of a letter sent to Mr. Kent C.\ninterpretation from these letters and a careful review of §§ 393.65 and 393.69 of the Federal Motor Carrier\nparticular (49.CFR §171.8), that the truck does not need place carding because it is considered a fuel system\nSafety Regulations (FMCSR), and the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) in\nunder the §393.65 part (a.) of the FMCSR.\nBecause there is nothing specifically stating the use of place cards I am asking you to reply with your\ncomments regarding my interpretation.\nSincerely,\nmit Athomas\nEngineering\nMilo A. Thomas\nMRL Equipment\n1s 374-91\nmateris?\nZ: \\Milo\\Documents\\Document Log\\US DoT 11.11.02.doc\nPHONE: 43854900 AX: 406890-88304\nINTERS WALNGS, MIT 5910\nSOUTHGATE DR","truncated":false,"body_characters":3615}