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OOSC, Part III, Item 3. Bulk Packages, f. Supports and Anchoring - Non-Spec Tanks

Entry DateFebruary 20, 2024
Issue Number24-011-HAZ
NameRobert Strauss
AgencyColorado State Patrol - Port of Entry
Address600 8th StMonument, co, 80132United StatesMap It (opens in a new tab)
Phone719-481-2281
Fax(719) 481-2494
Email[email protected]
CommitteeHazardous Materials Committee
StatusClosed
Summary of Issue

Hazmat - a 3 axle truck with a spec tank (I.E. 406 or 407) attached hauling diesel or gasoline has a specific violation for Supports and Anchoring. If you had the same 3 axle truck with a non spec tank (same size) attached hauling diesel or gasoline (bulk package) there is no specific regulation for Supports and anchoring. It still has to be marked per hazmat regulations, but there is no regulation for non spec tanks concerning supports and anchoring. The only note in the out of service manual concerning cargo securement is for intermodal containers. It would be considered out of service if 25% of the supporting or anchoring mechanisms are ineffective, but there is no regulation to cite for this non spec tank and there is for a spec tank.

Justification or Need

It would be considered out of service if 25% of the supporting or anchoring mechanisms are ineffective, but there is no regulation to cite for this on a non spec tank and there is for a spec tank. So how would you place it out of service when you have no regulation to cite on a non spec tank? There is no specific regulation to cite even if there is less than 25% of the supporting or anchoring mechanisms are ineffective on a non spec tank.

Request for Action

Create a violation for support and anchoring mechanisms specifically for a non spec tank so a violation could be cited on an inspection.