Display of Identification Numbers on Bulk Tanks
Pipeline and Hazardous Materials Safety Administration · Mar 1, 1982 · Reference No. 82-0002
Interprets: 49 CFR § 172.300, 49 CFR § 172.326, 49 CFR § 172.328, 49 CFR § 172.330, 49 CFR § 172.336
This is in reference to your letter of February 17, 1982, relative to the display of identification numbers on portable tanks, cargo tanks and tank cars transporting bulk materials.
The Hazardous Materials Regulations do not differentiate between liquids, gases and solids in § 172.300 which contains the basic marking requirements. Further, there is no differentiation between the basic marking requirements for liquids, gases and solids in §§ 172.326, 172.328 and 172.330. Therefore, if a packaging meets the definition of a portable tank, cargo tank or tank car and is used to transport hazardous material subject to 49 CFR Parts 100-177, the appropriate identification number display is required.
In general terms, cargo tanks are considered to be liquid tight and, therefore, could transport dry material or a solid that is loaded and unloaded as a liquid at an elevated temperature. Also, Specifications 56 and 57 are identified as portable tank specifications. Other bulk transport vehicles such as dump trucks, tube trailers, and hopper cars and trucks were omitted from the identification number marking requirements; however, under § 172.336(a) such numbers may be displayed on any of these vehicles when transporting hazardous materials.
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.