Prior to 1987, the DOT Hazardous Materials regulations (HMR) did not contain definitions for "bulk packaging" or "non-bulk packaging" - although historically certain requirements of the HMR were specifically made applicable on the basis of whether or not a packaging in which a hazard material was contained had "a capacity of 110 gallons or less". As the HMR developed and additional marking and other requirements were added (e.g., requirements to display ID numbers), DOT "discovered that several vehicles and packagings were not covered by the identification number marking regulations". To address this issue, in a notice of proposed rulemaking published in September 1984 under Docket No. HM-126D, DOT proposed the addition of a definition for "bulk packaging" to the HMR. Rather than the traditional 110 gallon "breakpoint", to be consistent with the UN definition for a portable tank DOT proposed to use 118.8 gallons (450 liters) as a minimum capacity for defining a bulk packaging.
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