{"operation":"document","citation":"00-0066","title":"Allied Universal Corp. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-03-17","effective_on":null,"summary":"00-0066 response to Allied Universal Corp. concerning 173.31.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0066.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0066.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0066","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000066.pdf","body":"<<<PAGE 1>>>\n\n•\nof Transportation\nJ.S. Department\n400 Seventh Street, S.W\nWashington, D.C. 2059(\nSeeta Programs\nMAR 17 2000\nAdministration\nMs. Robin J. Eddy\nSafety and Regulatory Compliance Manager\nRef. No. 00-0066\n8350 N.W. 93 Street\nAllied Universal Corp.\nMiami,\nFlorida 33166-2098\nDear Ms. Eddy:\nThis is in response to your letter of February 24, 1999,\nrequesting clarification of the retest and marking requirements\nfor DOT specification 106A500X multi-unit tank car tanks under\nthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nYour questions are paraphrased\n(Q1) Must a testing\nidentification number (RIN) to perform retesting under\nfacility possess a valid retester\n$ 180.519?\n(Al) No. RIN numbers are only assigned to authorized\ncylinder requalifiers.\n(22) Is a retester prohibited from stamping his RIN number\nmulti-unit tank car tank that successfully\ncompletes the required pressure test?\n(A2) No, the HMR do not prohibit the placement of a RIN\nnumber on a tank car, nor is it required.\n(23) Multi-unit tank car tanks are required to be marked\n, when is the\n(A3) As specified in § 180.519 (a), a retest may be made at\nany time during the calender year the retest falls due.\nTherefore, in your scenario, the retest may be\nconducted by December 31, 2001.\n000066\n173.31\n\n<<<PAGE 2>>>\n\n•\nI trust this satisfies your inquiry.\nbe of further\nassistance.\nPlease contact us if we can\nSincerely,\nHotte z Mitthe\nHattie I. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nstevens\nALLIED UNIVERSAL CORP\n* 030 w. as steal, Man, Fronted\nFax 305-885-4671\n305-AB9-2823\nFebruary 24. 2000\nMr. Edward Mazzulo\nU.S DO.T/RSPA\nVIA FASCIMILE: 202-366-3012\n400 Seventh Street, S.W\nWashington, D.C. 20590\nRe: Multi-Unit Tank Car Tanks, DOT Specification 106A500X\nDear Mr. Mazzulo:\nMaterials Enforcement Specialist, gave a presentation to all attendees on the DOT regulatory\nDuring a Chlorine Institute seminar in Charlotte, North Carolina, Cheryl K. Johnson, Hazardous\nrequirements for 3A, 3AA cylinders and 106A500X multi-unit tank car tanks (commonly\ncompletion of hydrostatic testing for ton containers, DOT specification 106A500X.\nreferred to in the gas industry as ton containers). Ms. Johnson noted that upon successful\ncontainer is to be marked with the month and year of the test. The container is not to be\n. the\nmarked with a Retester Identification Number (RIN). Please clarify the following:\n1. A testing facility is not required to have a RIN Number to test 106A500X tanks?\n2. If a testing facility legally owns a RIN Number, and that testing facility retests 106A500X\ntanks, is it illegal for the test facility to stamp their RIN Number on a multi-unit tank car tank\nthat successfully passes a hydrostatic test?\nOne question was asked during the presentation that Ms. Johnson was unable to answer.\n3. Ton containers have the month and year of the hydrostatic test stamped on the chime of\nthe container. If a container successfully passed a hydrostatic test in 1-96, when must a\nretest for the container be completed in order to continue use of the container? January\n' 2001 or December 31°' 2001? Is it the year of expiration for the tan container or the\nmonth and year of expiration that determine when the hydrostatic test is due?\nThere is much confusion within the industry regarding these three questions. Therefore, I am\nasking for a documented emergency clarification. The Chlorine Institute has an annual\nfor packaging operations, I would like to have these three issues clarifled prior to the meeting.\nmeeting in Houston, Texas starting March 19%. As a member of the regulatory subcommittee\nIf you have any questions, please contact me at 800-981-6700, extension 183.\nThank you.\nsincer\nRobin d. Eddy\nAllied Universal Corporation\nSafety & Regulatory Compliance Manager\nTO d\nFA67-909-616","truncated":false,"body_characters":3862}