Utah Highway Patrol Vehicle Safety Section — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Vashinaton, D.C. 2059 00 Seventh Street, S.W Pipeline and Hazardous Materials Safety Administration JUN 15 2006 Senior Trooper Mr. Bradley W. Clayton Ref. No. 06-0116 Vehicle Safety Section Utah Highway Patrol 5500 West Amelia Earhart Dr. Suite 360 Salt Lake City, Utah 84116 Dear Mr. Clayton: This responds to your letter requesting clarification of the cargo tank test date markings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). ask whether the test date marking requirements ir Specifically, you § 180.415 (b) (2) may be satisfied by placing them on a metal plate bolted to an appurtenance such as a hose tube or a fender. As you are aware, § 180.415 (b) (2) requires test date markings on a cargo tank to be placed near the specification these required markings to the cargo tank body. Therefore, plate or anywhere on the front head. The intent is to affix the scenario you describe does not satisfy that requirement of the HMR. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Hitler. nitthell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials . Standards 180.41516) 060116#

Page 2Utah Highway Patrol Stevens COLONEL SCOTT T. DUNCAN Superintendent $180.415 (b) State of Utah JON M. HUNTSMAN, JR. Cargo Tanks Governor GARY R. HERBERT 06-0116 Lieutenant Governor To: U.S. Department of Transportation Research and Special Programs Administration 10 April, 2006 Office of Hazardous Materials Standards 400 Seventh St., S.W. Washington, D.C. 20590 From: Senior Trooper Bradley W. Clayton Utah Highway Patrol 5500 West Amelia Earhart Dr. Suite 360 Salt Lake City, Utah 84116 Topic: Cargo Tank Test Date Markings Section 180.415(b) states; "Each cargo tank must be durably and legibly marked, in English, following provisions: with the date (month and year) and the type of test or inspection performed, subject to the Section 180.415(b)(2) states; "The markings must be in letters and numbers at least 32 mm (1.25 inches) high, near the specification plate or anywhere on the front head Does the term "Each cargo tank" and "near the specification plate or anywhere on the front be displayed on a metal plate bolted to a cargo tank appurtenance such as a hose tube or fender? head" mean the marking must be on the tank shell itself or are the test date markings allowed to (This metal plate could easily be removed by bolts and affixed to a different cargo tank) Thank you for considering this question Sincerely Bute Clat Senior Trooper Utah Highway Patrol Vehicle Safety Section 4501 South 2700 West, Box 141100, Salt Lake City, Utah 84114-1100 telephone 801-965-4379 • facsimile 801-965-4716#