National Tank Truck Carriers, Inc. — Hazardous Materials Safety Interpretation

Page 1174 : Kas int - U.S.Department of Transportation Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Special Programs Administration • Mr. John L. Conley APR 3" 1998 Vice President National Tank Truck Carriers, Inc. 2200 Mill Road Alexandria, VA 22314-4677 Dear Mr. Conley: This is in response to your request for clarification of certain requirements for cargo tank motor vehicles in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180). Your questions are paraphrased and answered as follows: Q1. When a carrier has to perform a periodic test or inspection as required by § 180.407(c), does the carrier have until the last day, of the month or must the next test or inspection be performed based on the exact date as the previous test or inspection? Al. A carrier has until the last day of the month and year in which the inspection or test is due. For example, if a test or inspection report reflects that an external visual inspection was performed on January 15, 1994, the carrier has until January 31, 1995, to perform the required test or inspection. Q2. Section 172.328(b) requires that each cargo tank transporting a Class 2 material must be marked on each side and each end with the proper shipping name of the product being transported, can the proper shipping name be displayed on the cargo tank itself or on a sign bracket installed on the cargo tank? ! A2. Either method may be used to display the proper shipping name on the cargo tank. Q3. In the case of a bobtail tank truck, i.e. the cargo tank is mounted on a truck chassis, can the marking be displayed on the cargo tank itself or on the front of the cab? A3. Display of the shipping name on the front bumper of the motor vehicle hauling a cargo tank does not satisfy the marking requirement in § 172.328(b). For gases such as "Propane," the shipping name must be marked and displayed in lettering, no less than 50 mm (2.0) inches), on each side and each end of the cargo tank. 180.407 98 - 0579 180.417#

Page 2• i Q4. In the case of a tractor semi-trailer combination, can the marking be displayed on the cargo tank itself or on the front of the cab? A4. See answer A3 above. midden. I hope this information is helpful and I apologize for the delay in responding. If we can be of further assistance, please contact us. Sincerely, Thome ts Allen, Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 3APR 3 1998 Mr. John L. Conley Vice President National Tank Truck Carriers, Inc. 2200 Mill Road Alexandria, VA 22314-4677 Dear Mr. Conley: This is in response to your request for clarification of certain requirements for cargo tank motor vehicles in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180). Your questions are paraphrased and answered as follows: Q1. When a carrier has to perform a periodic test or inspection as required by § 180.407(c), does the carrier have until the last day of the month or must the next test or inspection be performed based on the exact date as the previous test or inspection? Al. A carrier has until the last day of the month and year in which the inspection or test is due. For example, if a test or inspection report reflects that an external visual inspection was performed on January 15, 1994, the carrier has until January 31, 1995, to perform the required test or inspection. Q2. Section 172.328(b) requires that each cargo tank transporting a Class 2 material must be marked on each side and each end with the proper shipping name of the product being transported, can the proper shipping name be displayed on the cargo tank itself or on a sign bracket installed on the cargo tank? A2. Yes, either method may be used to display the proper shipping name on the cargo tank. Q3. In the case of a bobtail tank truck, i.e. the cargo tank is mounted on a truck chassis, can the marking be displayed on the cargo tank itself or on the front of the cab? A3. Display of the shipping name on the front bumper of the motor vehicle hauling a cargo tank does not satisfy the marking requirement in § 172.328(b). For gases such as "Propane," the shipping name must be marked and displayed in lettering, no less than 50 mm (2.0) inches), on each side and each end of the cargo tank.#

Page 4In the case of a tractor semi-trailer combination, can the marking be displayed on the cargo tank itself or on the front of the cab? A4. See answer A3 above. I hope this information is helpful and I apologize for the delay in responding. If we can be of further assistance, please contact us. Sincerely, Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards Karim:jk:dhm-10:64488:03/24/98 File: 180.407(c)/180.417(b) Revised:ta/em:3/30/98 SC:#

Page 5NATIONAL TANK NTTC NATIONAL TANK TRUCK CARRIERS, INC. TRUCK CARRIERS THE NATIONAL ORGANIZATION SERVING THE POR•HIRI TANK TRUCK INDUSTRY CLIFFORO J. MARVISON PRESIDENT 2200 MILL ROAD • ALEXANDRIA. VA 22314-467 PHONE: 703/838-1960 • FAX: 703/684-575: June 12, 1997 Mr. Ed Mazzullo Office of Hazardous Materials Standards Research and Special Programs Administration 400 7th St. S.W. Washington DC 20590 Dear Mir. Mazzullo: • National Tank Truck Carriers would appreciate an interpretation for the following situations: Section 172.328 (b) "Required Markings; Gases," states that each cargo tank transporting a Class 2 material must be marked on each side and each end with the proper shipping name of the product transported. 1. OR on a sign bracket installed on the cargo vessel (trailer or bobtail). Our interpretation is that the proper shipping name could be displayed on the cargo vessel itself 2. chassis) the marking could be displayed on front of the chassis cab and the yehicle would be Our interpretation is that in the case of a bobtail delivery truck (cargo tank mounted on truck in compliance. Our interpretation is that in the case of a tractor-semi-trailer combination, the marking could be displayed either on the front of the cargo tank OR on the front of the tractor and the vehicle • would be in compliance. Please advise if our interpretations are correct. Thank you for your consideration. Sincerely, Jolm 2 Conley John L. Conley Vice President#

Page 6105 NATIONAL TANK NTTC NATIONAL TANK TRUCK CARRIERS, INC. TRUCK CARRIERS THE NATIONAL ORGANIZATION SERVING THE FOR HIRE TANK TRUCK INOUSTAY CLIFFORD J. HARVISON PRESIOENT 2200 MILL ROAD • ALEXANDRIA, VA 22314.4677 PHONE: 703/838-1960 • FAX: 703/684-5753 January 17, 1995 Mr. Edward Mazzullo Office of Hazardous Materials Standards (DHM-10) 400 7th St. SW Research and Special Programs Administration Washington D.C. 20590 Dear MI. Mazzullo: This is a follow-up, request to submitted by NTTC on June 4, 1993. No answer has been received. request for interpretation Section 180.417 (b) (1) (iv) states that each cargo tank tested OL report that includes the reinspected as specified in "Test Date (Month and Year..) Likewise, 180.407 must have a written 180.415 requires that the cargo tank be marked with the date (month and year) of the inspection. While there is no requirement (of which we are aware) that carriers do lecord the DAY of inspection, along with the requires the carrier to record the DAY of the inspection, some and year. We have received violation oi 180.407 because the calls from carriers cited for month completed within test one year (of whatever interval applies) to the or inspection was not EXACI day Of the inspection/test due month. FoI example, a carrier may have inspection on January 15, 1994. It is our belief that the performed an external visual carrier has until the end of January 1995 to complete the next must have been completed by January 15, 1995. inspection, but some carriers have been told that the inspection QUESTION: inspection/ test due Does a carrier have until the last day of the accordance with 180.407? month to perform a test or inspection in Sincerely, ohn I. Confer Vice President CC: Alan Roberts Ron Kirkpatrick#