PHMSA letter of interpretation

Placarding Requirements for Propane Storage Tanks

Pipeline and Hazardous Materials Safety Administration · Dec 22, 1999 · Reference No. 99-0262

PHMSA says to use caution with this letter.

Interprets: 49 CFR § 172.514

Reggie’s quick take

Someone asked how to placard propane storage tanks under the Hazardous Materials Regulations. The agency says propane storage tanks must be placarded on each side and each end under § 172.514. However, § 172.514(c) allows labeling instead of placarding for a bulk packaging with a capacity of less than 18 cubic meters (640 cubic feet). The letter says the asker's tank is a bulk packaging under that size, so it qualifies for this exception.

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 is in response to your letter dated October 26, 1999, and subsequent phone conversations Mr. Michael Johnsen of my staff concerning placarding requirements for your propane storage tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Propane storage tanks must be placarded on each side and each end as required in § 172.514. However, § 172.514(c) provides an exception which allows labeling instead of placarding for certain portable tanks, DOT 106 and 110 multi-unit tank bars, IBCs and bulk packagings with a volumetric capacity of less,than 18 cubic meters (640 cubic feet). Your tank is a bulk packaging which has a volumetric capacity of less than 18 cubic meters, thus eligible for this exception.

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.