Trinity Industries, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Nashington, D.C Research and Special Programs Administration MAR 2 8 2000 Mr. Greg McRae, Quality Assurance Reference No. 00-0079 Trinity Industries, Inc. P.O. Box 588887 Dallas, TX 75358 Dear Mr. McRae: This is in reference to your letter addressed to Mr. Charles Hochman, Office of Hazardous Materials Technology, concerning specification shortages on a cargo tank manufactured to the MC 331 specification. You inquired whether your company may manufacture the cargo tank only and stamp "MC 331" on the metal identification plate. The assembler (i.e., cargo tank motor vehicle manufacturer) would stamp the original test date on the identification plate after all other specification requirements have been met. The answer is yes, the identification plate may be stamped with the specification number. For the MC 331 specification, the cargo tank is an ASME Code "U" stamped tank fitted with all appurtenances, reinforcements, fittings, and closures affecting lading retention installed by the cargo tank manufacturer. See definition of "cargo tank" in 49 CFR 178.320. The MC 331 specification in § 178.337 does not preclude the manufacture of a cargo tank motor vehicle in stages with the work performed by different manufacturers. Marking the original test date and the specification number on a cargo tank's metal identification plate certifies that the cargo tank conforms to the applicable specification. Your company must provide the ASME manufacturer's data report and related documents to the cargo tank motor vehicle manufacturer. The certificate of compliance stating that the completed cargo tank motor vehicle conforms in all respects to the MC 331 specification would be completed by the cargo tank motor vehicle manufacturer, as specified in § 178.337-18. The registration numbers of the manufacturer, the Design Certifying Engineer and the Registered Inspector, as appropriate, must appear on the certificates. I hope this information is helpful. IfI can be of further assistance, please contact me. Sincerely, Halte z, mittell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 178,345-15 000079#

Page 2Mitche !! 5178,345-15 : TRINITY INDUSTRIES, INC. CHARLES HockmAN 00-0079 April 27, 1999 DO YOU IAVE AN ANSWER? Fax --202-366-3753 THANKS Mr. Charles Hochman U.S. Department Of Transportation GREE MERAE Hazardous Materials Safety Washington, D.C. 20590-0001 3-6-00 Subject: Clarification Of Specifications Dear Mr. Hochman: At the present time specificatlon MC-331 does not address "Specification Shortages" as addressed in paragraph 178.345-15(e) for MC-405 specification contalners. Trinity manufactures truck and transport tanks only and does not manufacture complete motor vehicles. i We would like to stamp the nameplate MC-331 and let the vehicle manufacture stamp the "Test Date'' after all other requirements have been met. Can Trinity apply paragraph 178.345-15(e) to MC-331 products? ... ? manita Nata repir 1-stm Quality Assurance certient Cc: Keith Culhane James Roberts Tom Alkens GMits F:/pa/shara/gsec/strugg/greg/USDept Of Trans. Charles Hochman/ 2526 STEMMONS FREEWAY • DALLAS. TEXAS 76207 • POST OFFICE BOX 56B687 • DALLAS, TEXAS 75356-8887 (214) 631.4420 • FAX (214) 588-8501#