Effective July 8, 2011, the FMSCA changed the definition of a “tank” vehicle which impacts the transport of multiple bulk containers, i.e. tote tanks or dewars, for all commodities. The original definition was focused on containers that were permanently or temporarily attached to a vehicle or chassis excluding portable tanks/dewars.
The new definition now includes the previously excluded portable tanks/dewars and is phrased to account for the “aggregate rated capacity” of multiple containers totaling 1,000 gallons or more will require the driver to have a tank endorsement (N) on their license to haul these shipments. For example, if a driver were to have 10 tote tanks, and each tank had a capacity of 119 gallons, the total aggregate rated capacity of shipment would be 1,190 gallons. This would exceed the 1,000 gallon requirement in the new tank definition, and the driver would need the tank endorsement to haul this shipment.
How many expediters who do not currently have an "N" or "X" endorsement on you license are planning on doing so? How many feel that they handle enough of that type of freight to make it worth the effort?