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Interpretation Response #19-0099

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 10-08-2019
Company Name: ACA International LLC    Individual Name: Tim Farrell
Location state: MA    Country: US

View the Interpretation Document

Response text:

October 8, 2019

Tim Farrell
ACA International LLC
129 Newbury Street
Boston, MA 02116

Reference No. 19-0099

Dear Mr. Farrell:

This letter is in response to your August 6, 2019, email and subsequent phone call requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to transportation of a cargo tank motor vehicle (CTMV) on a removeable gooseneck (RGN) trailer.  Specifically, you ask whether the HMR prohibits the transportation of a filled or partially filled CTMV on a RGN trailer.

The answer is no, the HMR does not prohibit the transportation of a filled or partially filled CTMV on a RGN trailer. Please note that all applicable HMR requirements, including hazard communication such as markings and placards, continue to apply when the filled or partially filled CTMV is the object of carriage, rather than the actual vehicle used to transport the hazardous material cargo. Also, please be aware that § 177.834(a) requires that the CTMV be secured against shifting during transportation while loaded on the RGN trailer.

I hope this information is helpful. Please contact us if we can be of further assistance.


Dirk DerKinderen
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
§ 177.834 General requirements