Fuel tanks permanently mounted on a motor vehicle
Pipeline and Hazardous Materials Safety Administration · Feb 23, 2009 · Reference No. 08-0171
Interprets: 49 CFR § 171.8
Reggie’s quick take
A company asked whether four 119-gallon fuel tanks permanently mounted on a truck bed and connected by permanently mounted fuel lines count as a non-bulk packaging under § 171.8. PHMSA said no. For the HMR, this setup is a single bulk packaging of 476 gallons, so it is not a non-bulk packaging. It also meets the definition of a cargo tank, so it must meet all applicable HMR requirements when used to transport hazardous materials.
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 June 24, 2008 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to fuel tanks permanently mounted on a motor vehicle. Specifically, you ask if four 119-gallon tanks permanently mounted on the bed of a truck and connected together with permanently mounted fuel lines meets the definition for a non-bulk packaging in § 171.8 of the HMR.
The answer is no. For purposes of the HMR, the fuel tank configuration described in your letter is considered a single bulk packaging with a capacity of 476 gallons. The unit does not meet the definition of "non-bulk packaging" due to its overall capacity. Please note that, under the HMR, the fuel tank configuration described in your letter meets the definition for a cargo tank and must meet all applicable HMR requirements if used to transport hazardous materials. See § 171.8 for the definition of "cargo tank."
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.