dot test for fab-shop fuel tank

Discussion in 'Trucking Industry Regulations' started by wulfman76, Jul 13, 2010.

  1. wulfman76

    wulfman76 Bobtail Member

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    May 17, 2010
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    Hello,
    I would like to build a custom set of gasoline fuel tanks to mount on the back of the truck so that i can have a gasoline suppply at the job site. I'm wanting to know if there is a specific test, like the 3psi test, that satisfies DOT requirements for these tanks.

    I thought about just using 2 or 3 salvaged saddle tanks from older trucks but they say "DOT approved for Diesel fuel only"

    Any info or ideas would be appreciated.
    Thanks
     
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  3. scottied67

    scottied67 Road Train Member

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    Typically there is a gallon limit for auxillary fuel tanks in the back of worktrucks .If it is California I think it is 100 gallons. Also illegal to carry gasoline in them, only diesel fuel.

    Back in the 70's my dad had a welding shop and would build many things, but I do remember he built some gasoline tanks with I think was 3/16ths plate. The test they put it through was to fill it with water to check for leaks.
     
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  4. rightlane4trucking

    rightlane4trucking Light Load Member

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    Mount Shasta, California
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    My advise to you would be to abandon the idea of fabricating (or modifying) a tank for your requirements.

    Gasoline is a class 3, Packing Group II material. As such the requirements for authorized packaging are contained in 49CFR173.202 (for nonbulk - up to 119 gallons) and 49CFR173.242 (for bulk packages - over 119 gallons).

    Additionally, all of the other hazardous materials transportation regulations would apply; IE: shipping papers, emergency response information, mandated hazardous materials employee training, placarding & a CDL endorsement if you exceed 1001 pounds).

    As I see it, you have 2 options for getting gasoline to your job site. Which option would make the most sense for you will depend upon your job circumstances (how much gasoline will you need for equipment on a daily basis and what is the duration of the job)

    Option 1
    Transport gasoline to the job site as needed under the "Materials of Trade" exemption.

    Material of trade means a hazardous material, other than a hazardous waste, that is carried on a motor vehicle—
    (1) For the purpose of protecting the health and safety of the motor vehicle operator or passengers;
    (2) For the purpose of supporting the operation or maintenance of a motor vehicle (including its auxiliary equipment); or
    (3) By a private motor carrier (including vehicles operated by a rail carrier) in direct support of a principal business that is other than transportation by motor vehicle.


    The requirements for authorized transportation as a "MOT" are contained in 49CFR173.6. The text that I've formatted in red would apply to your situation.
    § 173.6 Materials of trade exceptions.

    [​IMG] top When transported by motor vehicle in conformance with this section, a material of trade (see §171.8 of this subchapter) is not subject to any other requirements of this subchapter besides those set forth or referenced in this section.
    (a) Materials and amounts. A material of trade is limited to the following:
    (1) A Class 3, 8, 9, Division 4.1, 5.1, 5.2, 6.1, or ORM-D material contained in a packaging having a gross mass or capacity not over—
    (i) 0.5 kg (1 pound) or 0.5 L (1 pint) for a Packing Group I material;
    (ii) 30 kg (66 pounds) or 30 L (8 gallons) for a Packing Group II, Packing Group III, or ORM-D material;
    (iii) 1500 L (400 gallons) for a diluted mixture, not to exceed 2 percent concentration, of a Class 9 material.
    (2) A Division 2.1 or 2.2 material in a cylinder with a gross weight not over 100 kg (220 pounds), or a permanently mounted tank manufactured to the ASME Code of not more than 70 gallon water capacity for a non-liquefied Division 2.2 material with no subsidiary hazard.
    (3) A Division 4.3 material in Packing Group II or III contained in a packaging having a gross capacity not exceeding 30 mL (1 ounce).
    (4) A Division 6.2 material, other than a Category A infectious substance, contained in human or animal samples (including, but not limited to, secreta, excreta, blood and its components, tissue and tissue fluids, and body parts) being transported for research, diagnosis, investigational activities, or disease treatment or prevention, or is a biological product or regulated medical waste. The material must be contained in a combination packaging. For liquids, the inner packaging must be leakproof, and the outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packaging. For sharps, the inner packaging (sharps container) must be constructed of a rigid material resistant to punctures and securely closed to prevent leaks or punctures, and the outer packaging must be securely closed to prevent leaks or punctures. For solids, liquids, and sharps, the outer packaging must be a strong, tight packaging securely closed and secured against shifting, including relative motion between packages, within the vehicle on which it is being transported.
    (i) For other than a regulated medical waste, the amount of Division 6.2 material in a combination packaging must conform to the following limitations:
    (A) One or more inner packagings, each of which may not contain more than 0.5 kg (1.1 lbs) or 0.5 L (17 ounces), and an outer packaging containing not more than 4 kg (8.8 lbs) or 4 L (1 gallon); or
    (B) A single inner packaging containing not more than 16 kg (35.2 lbs) or 16 L (4.2 gallons) in a single outer packaging.
    (ii) For a regulated medical waste, a combination packaging must consist of one or more inner packagings, each of which may not contain more than 4 kg (8.8 lbs) or 4 L (1 gallon), and an outer packaging containing not more than 16 kg (35.2 lbs) or 16 L (4.2 gallons).
    (5) This section does not apply to a hazardous material that is self-reactive (see §173.124), poisonous by inhalation (see §173.133), or a hazardous waste.
    (b) Packaging. (1) Packagings must be leak tight for liquids and gases, sift proof for solids, and be securely closed, secured against shifting, and protected against damage.
    (2) Each material must be packaged in the manufacturer's original packaging, or a packaging of equal or greater strength and integrity.
    (3) Outer packagings are not required for receptacles (e.g., cans and bottles) that are secured against shifting in cages, carts, bins, boxes or compartments.
    (4) For gasoline, a packaging must be made of metal or plastic and conform to the requirements of this subchapter or to the requirements of the Occupational Safety and Health Administration of the Department of Labor contained in 29 CFR 1910.106(d)(2) or 1926.152(a)(1).
    (5) A cylinder or other pressure vessel containing a Division 2.1 or 2.2 material must conform to packaging, qualification, maintenance, and use requirements of this subchapter, except that outer packagings are not required. Manifolding of cylinders is authorized provided all valves are tightly closed.
    (c) Hazard communication. (1) A non-bulk packaging other than a cylinder (including a receptacle transported without an outer packaging) must be marked with a common name or proper shipping name to identify the material it contains, including the letters “RQ” if it contains a reportable quantity of a hazardous substance.
    (2) A bulk packaging containing a diluted mixture of a Class 9 material must be marked on two opposing sides with the four-digit identification number of the material. The identification number must be displayed on placards, orange panels or, alternatively, a white square-on-point configuration having the same outside dimensions as a placard (at least 273 mm (10.8 inches) on a side), in the manner specified in §172.332 (b) and (c) of this subchapter.
    (3) A DOT specification cylinder (except DOT specification 39) must be marked and labeled as prescribed in this subchapter. Each DOT-39 cylinder must display the markings specified in 178.65(i).
    (4) The operator of a motor vehicle that contains a material of trade must be informed of the presence of the hazardous material (including whether the package contains a reportable quantity) and must be informed of the requirements of this section.
    (d) Aggregate gross weight. Except for a material of trade authorized by paragraph (a)(1)(iii) of this section, the aggregate gross weight of all materials of trade on a motor vehicle may not exceed 200 kg (440 pounds).
    (e) Other exceptions. A material of trade may be transported on a motor vehicle under the provisions of this section with other hazardous materials without affecting its eligibility for exceptions provided by this section.


    My recommendation would be to obtain the necessary number of 5 gallon OSHA approved gas cans, do not exceed 440 pounds aggregate gross weight and transport the gasoline to the job site as needed.

    Option 2
    If this is a long term job, and option 1 is not practical, you could consider purchasing or renting an above-ground gasoline storage tank to be placed at the job site and have your fuel delivered.

    As pointed out by scottied67, this issue would be a lot less complicated if you were talking about diesel fuel (a combustible liquid) rather than gasoline (a flammable liquid).
     
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  5. GasHauler

    GasHauler Master FMCSA Interpreter

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    I do not understand why you would need alot of gasoline at a jobsite. Just about all the equipment is diesel and any other gasoline powered equipment is small powered engines. But I do not know what you're doing. I would recomment just going to a salvage store or any where you can find the old 5 gallon jerry cans we used in the military. They're cheaper than building a tank or even buying ready made gasoline cans. Store just enough to where you don't need to follow the hazmat rules and you're ready to go.
     
  6. wulfman76

    wulfman76 Bobtail Member

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    May 17, 2010
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    Thanks rightlanetrucking.

    Looks like a royal pain in the #####. This gas will be for our own use so i think it would fall under the materials of trade section but the limit of 8 gallons or 440 pounds seems very restrictive.

    Currently we use about 150 gallons per day or around 1000lbs and without getting into to much detail we have to be mobile as we have served up to 25 locations a day up to 40 miles in any direction.

    Several of our competitors have their own custom made stainless tanks of around 250 gallons that they have been using for years. I ask them about it and they just say they've been lucky no one has stopped them yet.

    There has to be a legal way to do this.....right?

    Double wall tank, something?
    Thanks
     
  7. rightlane4trucking

    rightlane4trucking Light Load Member

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    I wish I had a magic bullet for you, but I don't. Based upon your description of your operation I still think that complying with the material of trade requirements would be the best way to legally meet your needs. I understand that the quantity limitations in 173.6 would require that you alter the way that you deliver your gasoline. It would be less convenient and less efficient (would require multiple delivery vehicles or multiple trips to meet your needs).

    Although I do not know in which state you are operating, it probably doesn't matter since the feds regulate the intrastate transportation of hazardous materials for "commercial purposes".

    Your competitors are running a huge risk. 250 gallons puts them up around 1800 pounds of gasoline. The potential penalties could easily run into the 10's of thousands of dollars.
     
  8. Passin Thru

    Passin Thru Road Train Member

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    You can transport gasoline in a properly marked, DOT approved container and it must have Flammable and the hazmat # on ea side of the tank. It dust be of a type that you draw from the top with a pump and it must have a switch in reach of the person operating it if it is an electric refueling pump. It must be bolted to the vehicle and protected inside the body such as railing, pickup bed, etc You must carry a Class A Fire extinguisher with you, within easy reach. That is the law. Ask a farmer how they carry gas. We use a 110 ga. tank on a pickup and have never been asked except what color is the fuel in it.
     
  9. rightlane4trucking

    rightlane4trucking Light Load Member

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    Mount Shasta, California
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    We must exercise caution when offering this kind of advice.
    1. You are describing the transportation of a hazardous material by an agricultural operation which is entitled to a specific exemption to the federal regulations (I will include the text of the exemption below). I do not believe that wulfman76 is engaged in a farming operation.
    2. Even if he was, the intrastate requirements in his state may be different from Virginia (we still don't know in which state wulfman76 is operating).

    Here is the reason that a farming operation can do it differently from other businesses:

    Title 49: Transportation
    PART 173'SHIPPERS'GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS
    Subpart A'General


    § 173.5 Agricultural operations.

    (a) For other than a Class 2 material, the transportation of an agricultural product over local roads between fields of the same farm is excepted from the requirements of this subchapter. A Class 2 material transported over local roads between fields of the same farm is excepted from subparts G and H of part 172 of this subchapter. In either instance, transportation of the hazardous material is subject to the following conditions:
    (1) It is transported by a farmer who is an intrastate private motor carrier; and
    (2) The movement of the agricultural product conforms to requirements of the State in which it is transported and is specifically authorized by a State statute or regulation in effect before October 1, 1998.
    (b) The transportation of an agricultural product to or from a farm, within 150 miles of the farm, is excepted from the requirements in subparts G and H of part 172 of this subchapter and from the specific packaging requirements of this subchapter when:
    (1) It is transported by a farmer who is an intrastate private motor carrier;
    (2) The total amount of agricultural product being transported on a single motor vehicle does not exceed:
    (i) 7,300 kg (16,094 lbs.) of ammonium nitrate fertilizer properly classed as Division 5.1, PG III, in a bulk packaging, or
    (ii) 1900 L (502 gallons) for liquids or gases, or 2,300 kg (5,070 lbs.) for solids, of any other agricultural product;
    (3) The movement and packaging of the agricultural product conform to the requirements of the State in which it is transported and are specifically authorized by a State statute or regulation in effect before October 1, 1998; and
    (4) Each person having any responsibility for transporting the agricultural product or preparing the agricultural product for shipment has been instructed in the applicable requirements of this subchapter.
    (c) Formulated liquid agricultural products in specification packagings of 220 L (58 gallons) capacity, or less, with closures manifolded to a closed mixing system and equipped with positive dry disconnect devices may be transported by a private motor carrier between a final distribution point and an ultimate point of application or for loading aboard an airplane for aerial application.
    (d) See §173.315(m) pertaining to nurse tanks of anhydrous ammonia.
    (e) See §173.6 pertaining to materials of trade.
    (f) See §172.800(b) pertaining to security plans.
    [Amdt. 173-259, 62 FR 1215, Jan. 8, 1997, as amended by Amdt. 173-262, 62 FR 49566, Sept. 22, 1997; Amdt. 173-259, 63 FR 8142, Feb. 18, 1998; 65 FR 50460, Aug. 18, 2000; 70 FR 73165, Dec. 9, 2005; 73 FR 4717, Jan. 28, 2008]
     
    Last edited: Jul 29, 2010
  10. Powder Joints

    Powder Joints Subjective Prognosticator

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    Go buy a used gas truck at the local auction yard (such as Richie Brothers), get your hazmat CDL and what ever is required by the state your in and DOT compliance.

    Why re-invent the wheel.
     
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