This NON-CDL truck could require the driver to have a CDL with a Tank endorsement to drive
FMCSA definition for “Tank Vehicle” for Tank Endorsement for CDL
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.
Four of these 275 gallon IBC totes filled with liquid or gaseous materials would require the driver of the NON-CDL unit now to have a CDL with a tank vehicle endorsement as the totes exceed the 119 gallon tank definition and the aggregate capacity exceeds 1,000 gallons.