M-102 portable tanks
Pipeline and Hazardous Materials Safety Administration · Oct 29, 2007 · Reference No. 07-0184
Interprets: 49 CFR § 173.32
Reggie’s quick take
Someone asked about IM-101 and IM-102 portable tanks. Under § 173.32(c)(2), these tanks could not be manufactured after January 1, 2003. Tanks already in use may stay in service if they meet the HMR in effect on September 30, 2001, or the new "T" codes in § 172.102(c)(7)(i). They must also pass the periodic inspections and tests in Subpart G of Part 180. Tanks built after January 1, 2003 must meet the UN portable tank rules in §§ 178.274 through 178.277 and Part 180, Subpart G.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This responds to your September 13, 2007 letter requesting information on IM-102 portable tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
In accordance with §173.32(c)(2), DOT Specification 51, IM-l0l and IM-102 portable tanks may not be manufactured after January 1, 2003, but may continue in use provided they meet the requirements of the HMR in effect on September 30, 2001 or the new "T" codes in § 172.102(c)(7)(i). In addition, the tank must pass periodic inspections and tests specified for the particular portable tank in Subpart G of Part 180. After January 1, 2003, all newly constructed portable tanks must conform to requirements for the design, construction and approval of UN portable tanks as specified in § 178.274, 178.275, 178.276, 178.277 and Part 180, Subpart G, of the HMR.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.