We have several Hydrovac trucks. The tanks on these trucks are constructed where it holds 400-500 gallons of clean water in its natural state. The water is used as a pressure washer to spray the ground and the large vacuum sucks up the mud to prevent and fiber optics, water lines or gas lines underground from being damaged. During an inspection we were cited a 393.100 violation for a drip on clean water on the ground. The load in question is the water was not the load; the mud was the load. The water dripping in its natural state. Is this a violation? It was clean water that a valve was very slightly open. This was immediately corrected. My thoughts as an 18 plus Texas DPS Officer and Sergeant is that it is not. Please give me guidance. I have driven around and looked at water trucks both City and Construction leaking water, but never seen one cited for this. I also have seen gravel trucks leaking water from rain or being loaded from a quarry that leak water. I believe this is a very gray area and we need guidance.

Is water in its natural state, dripping from a hydrovac truck a violation

Please give your answer on this issue. I just believe that this needs to be addressed for both companies and enforcement.

Information received regarding the stop indicated that the truck was stopped in TX with clean water draining from tank. There was a steady stream of water coming from the hose. The driver was able to close the valve and the water stopped draining. The inspector cited a violation for water leaking, unsecured load, but did not place the vehicle OOS. It was clean water and not an imminent hazard. The issuer would like the forum to decide whether it is a violation and/or OOS. It was likened to hay trucks and losing flecks of hay and didn’t feel that this is a hazard. In this case, the violation could be corrected by closing the valve. A question was asked when this would be a violation, a broken valve or something that can’t be stopped. Discussion was whether this is a training issue or if an inspection bulletin is needed. These situations are difficult to make a black and white answer on and there needs to be common sense. Some saw this a violation, some didn’t. The majority indicated that it was a violation of 393.100 as the regulation indicates the load cannot be falling, blowing or dripping from the vehicle and the water was the cargo and it was dripping. This issue was closed with no further action.