On May 9, 2011 the FMCA expanded the definition of a Tank Vehicle to:
Tank vehicle means any commercial motor vehicle that is designed to transport any liquid or gaseous materials within a tank or tanks having an individual rated capacity of more than 119 gallons and an aggregate rated capacity of 1,000 gallons or more that is either permanently or temporarily attached to the vehicle or the chassis. A commercial motor vehicle transporting an empty storage container tank, not designed for transportation, with a rated capacity of 1,000 gallons or more that is temporarily attached to a flatbed trailer is not considered a tank vehicle.
Implication1: A shipment of IBC’s that individually have a capacity of more than 119 gallons and a total capacity of greater than 1000 gallons is now considered an Tank Vehicle, even if it’s in a van.
Implication2: The driver will now need a tank endorsement on their CDL (Commercial Drivers License)
Best Safety and Compliance Practise: Ensure that if you are shipping IBC’s to/from the US on a shipment that meets the definition of a Tank Vehicle, that the driver picking up the shipment has a Tank Endorsement on his CDL, much like shippers are verifying the Hazmat Endorsement and FAST card requirement for Hazmat Shipments.