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April 3, 2018 DOT Letters of Interpretation for Months of January and February 2018 Available in Reference Gateway: New Index for Ease of Use

By Journal StaffApril 3, 2018

Going forward, we are enhancing our service in the presentation of the letters with the following:

  • We will email subscribers following the issuance of the Digital Edition of The Journal with a link to a webpage at This link will take you a page containing a listing by 49 CFR section number (in ascending order) letters covered the preceding two months. January and February letters are presented in this reference.
  • Links to the applicable 49 CFR sections are provided, in addition to a link to a comment we may have made on that letter. Letters with our comments from our technical advisors are notated in the table.
  • You will also note that we have added originating letters to DOT’s responses so that you will have access to the full context of the questioner’s inquiry.
  • These web pages will be directly accessible in a new section from the pulldown US DOT menu, PHMSA Letters: Indexes by Issue

We will be happy to answer any questions you may have regarding this new feature presented by The Journal. Please do not hesitate to contact us with any questions, comments, or suggestions.

To view the below index in the Reference Gateway, click here. Login is required. Links to the letters themselves are provided there.

§§ 171.1(d)(6), 177.870, 175.10, 173.115(b)(1), February 20, 2018 Compressed gases in a refillable non-DOT specification container  Ref No. 17-0115
§§171.22(g), 171.22(g)(2), 172.704, 172.704(a), 172.704(a)(2)(ii), January 23, 2018 Training requirements for a person located outside the United States Ref No. 17-0100
§ 172.203, February 27, 2018 Air shipment of radioactive materials Ref No. 17-0114
§§172.504(c)(1), 172.505, 172.504(e), 171.8, 172.201(a)(4), 177.848(f), 177.848(g), January 23, 2018 Placarding, segregation, and shipping paper requirements Ref No. 17-0109
§§ 173.185(e), 173.185, February 16, 2018 Transportation of low production runs of lithium batteries Ref No. 17-0071
§§ 173.185(e)(4), 173.185(e)(3), January 23, 2018 Produces a non-UN tested prototype lithium battery contained in equipment Ref No. 17-0127
§§ 173.304b, 173.301(f), 173.304a(d)(3)(ii), February 5, 2018 PRD requirements for USDOT 2P or 2Q containers filled with butane Ref No. 17-0129
§ 173.308(e)(2), January 16, 2018 Private carriage exception for the shipment of lighters Ref No. 17-0097
§ 173.309, February 2, 2018 Fire suppression systems used in racing vehicles Ref No. 17-0087
§§ 173.4b, 173.4, 173.4(e), §§ 106.95, 106.100, 106.105, February 5, 2018 De minimis exception as pertains to the HM-215J/224D Final Rule Ref No. 17-0138
▶ §§ 175.10(a)(18), 173.159a(d), 175.10(a)(18)(iii), February 20, 2018 Carriage of non-spillable batteries on passenger aircraft Ref No. 17-0060
▶ § 177.848, 173.24a(c), 177.848(e)(6), February 14, 2018 Combinations of Class 3 and Division 5.1 materials are being offered for highway transportation Ref No. 17-0064
▶ §§ 178.273, 171.7, January 19, 2018 Design margin (safety factor) for UN portable tanks Ref No. 17-0083
§§ 178.70, 178.71, 178.69, 178.71(q), (r), 173.301, 173.301b, 173.304b, 180.207, 172.101, January 19, 2018 Carbon fiber composite cylinders with an aluminum liner Ref No. 17-0062
§ 178.71(d), February 5, 2018 Design and construction requirements for UN composite cylinders Ref No. 17-0107