Definition of a Tank Vehicle and Related Guidance
| Entry Date | January 30, 2014 |
|---|---|
| Issue Number | 14-005-DRV |
| Name | Russ Christoferson |
| Agency | Motor Carrier Services |
| Address | 2701 ProspectHelena, MT, 59620United StatesMap It (opens in a new tab) |
| Phone | 406-431-1269 |
| [email protected] | |
| Committee | Driver-Traffic Enforcement Committee |
| Status | Closed |
| Summary of Issue | A flatbed vehicle is hauling ten, 250 gallon totes full of a liquid. The totes are secured to a pallet and those pallets are strapped down to the flatbed trailer. Per the definition of a tank vehicle and the related guidance, this would be considered a tank vehicle and a tank endorsement is required. Now, the same totes are loaded within a van trailer. The totes have load locks to the rear and dunnage bags in between to prevent sliding within the van trailer. The question is, would this be considered a tank vehicle? The problem being that the load is not permanently or temporarily attached to the vehicle as it was with the load on the flatbed being strapped down. |
| Justification or Need | Plastic totes hauling liquid that are strapped to a flatbed can be considered temporarily attached to the vehicle. Putting a load in a reefer shouldn’t be a loophole. The intent of the law is so that liquid loads which can slosh back and forth should have specialized training for the CDL. It shouldn’t matter whether it’s loaded onto a flatbed or within a reefer. |
| Request for Action | Need a clarification or an interpretation that allows for totes full of liquid loaded within a van trailer to still meet the definition of a tank vehicle. |