Summary

In 2004, nurse tanks without the Department of Transportation (DOT) required identification plate from the manufacturer of the tank began to be placed out of service by DOT.

Background

In 2004, DOT enforcement personnel in the state of Maryland placed a fertilizer retailer’s nurse tanks out of service for failure to have a legible manufacturer’s identification plate.  After meetings with the fertilizer retailer, TFI and DOT, TFI filed an application at DOT for a “special permit.”  Special permits can be approved by DOT if an equivalent level of safety can be proven.  In the application TFI requested that nurse tanks with lost or illegible identification plates be allowed to remain in service if an external visual inspection and pressure test were passed.  In response to TFI’s petition, DOT approved a special permit but required an external visual, pressure and thickness test, and required these tests be performed every five years.

In Dec. 2008, TFI petitioned DOT to require this testing for all nurse tanks with or without the identification plate.

In 2011, DOT incorporated the requirements of the special permit into federal regulations at 49 CFR 173.315(m)(2).