HOYER Global (USA), Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 March 31, 2025 Payton den Herder Sales Manager HOYER Global (USA), Inc. 2100 Space Park Drive, Suite 200 Houston, TX 77058 Reference No. 24-0103 Dear Mr. den Herder: This letter is in response to your October 23, 2024, email and subsequent email conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to data plate marking requirements for United Nations (UN) portable tanks. Specifically, you describe a UN portable tank with a country of approval other than the United States (e.g., the Netherlands). The UN portable tank’s design was approved by an approval agency authorized to review and approve the design of UN portable tanks by the competent authority of the country of approval. The approval agency has also been authorized to approve the design of a UN portable tank by the competent authority of the United States (i.e., the Pipeline and Hazardous Materials Safety Administration (PHMSA)). The approval agency maintains valid approval numbers issued by both competent authorities. Is the UN portable tank’s data plate (see § 178.274(i)) required to display the approval number assigned by PHMSA, in addition to the approval number of the country of approval? No. The data plate of a UN portable tank marked with the United States as the country of approval must display the approval number issued by PHMSA to the approval agency. The data plate of a UN portable tank marked with a country other than the United States as the country of approval is subject to the regulations and requirements of that particular competent authority. UN portable tanks with a country of approval other than the United States may be used in the United States in accordance with § 173.24(d)—see previously issued Letters of#

Page 2Interpretation Reference Nos. 23-0004 and 13-0151, enclosed with this response. Moreover, regarding this scenario, the HMR does not restrict a person from permissively marking the approval number issued by PHMSA on the data plate. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Patrick 24-0103 From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: FW: Resending for formal letter of interpretation: US/DOT approval NO - IA identification number for Surveying company Date: Wednesday, October 23, 2024 2:54:23 PM Attachments: image002.png image003.png Hello Alice, Please see the below interpretation request. Let us know if you need anything. Sincerely, Janaye From: Payton Den Herder <P.DenHerder@HOYER-Group.com> Sent: Wednesday, October 23, 2024 12:31 PM To: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov>; INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Resending for formal letter of interpretation: US/DOT approval NO - IA identification number for Surveying company CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Good day Mr. Shane Kelley, Emailing to have in clear determination in writing on the below issue. For portable container (ISO container) hauling bulk liquid hazardous products. Would the CSC plate on the ISO container legally be required to have the below highlighted IA number which is an identifier number for the original approving (survey) agency. Thank you and best regards, Payton den Herder Sales Manager HOYER Global (USA), Inc.#

Page 42100 Space Park Drive, Suite 200 | Houston, TX 77058 | USA Phone +1 281 853 1085 | Mobile +1 281 798 0724 p.denherder@hoyer-group.com www.hoyer-group.com FMC Registration 019843N From: Payton Den Herder Sent: Wednesday, October 23, 2024 10:36 AM To: phmsa.hm-infocenter@dot.gov; infocntr@dot.gov Subject: US/DOT approval NO - IA identification number for Surveying company Good day, Checking regulations for hauling hazardous material with ISO containers. This is specifically in relation to 49 CFR, Section 107.402 and whether or not the identifier number for the original approving agency (IA number highlighted below as example) is required to be stamped on the data plate of the ISO container. Thank you and best regards, Payton den Herder Sales Manager HOYER Global (USA), Inc. 2100 Space Park Drive, Suite 200 | Houston, TX 77058 | USA Phone +1 281 853 1085 | Mobile +1 281 798 0724 p.denherder@hoyer-group.com www.hoyer-group.com FMC Registration 019843N ----------------------------------------------------------------------------------------------------------------- Applicable conditions: Unless agreed otherwise in writing, all activities are carried out by HOYER Global Transport B.V. ("HOYER“) exclusively in the capacity of forwarder (including acting as customs agent) , unless HOYER issues a HOYER Global Transport Combicon Bill of Lading („HOYER B/L“) in which case HOYER acts as a carrier. The Dutch Forwarding Conditions (FENEX), latest version, including a choice for Dutch Law and an arbitration clause, are applicable to all forwarding and other activities, unless HOYER acts as carrier under a HOYER B/L in which case the#

Page 5conditions of the HOYER B/L, including a choice for Dutch Law and a jurisdiction clause (court of Rotterdam), are applicable. The FENEX Conditions and Conditions of the HOYER B/L can be downloaded from www.hoyer-group.com and at request they will be sent to you free of charge. The information contained in this communication is confidential and may be legally privileged. It is intended solely for the use of the individual or entity to whom it is addressed and others authorised to receive it. If you are not the intended recipient you are hereby notified that any disclosure, copying, distribution or taking any action in reliance on the contents of this information is strictly prohibited and may be unlawful. HOYER Global Transport BV, its subsidiaries and all other companies within the HOYER Group are neither liable for the proper and complete transmission of the information contained in this communication nor for any delay in its receipt. Business Partners and Applicants please view our privacy policy on www.hoyer-group.com/en/data-privacy. Company: HOYER Global Transport Legal Form: B.V. Registered Office of Company: NL-3197 KJ Botlek ROTTERDAM, Oude Maasweg 50 Registration Number: 24113981 Court of Registration: Chamber of Commerce Rotterdam Managing Directors: Christian Berlin, David Goekoop, Elke van der Straate, Patrick de Heide#