{"operation":"document","citation":"00-0123","title":"Keehn Service Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-05-10","effective_on":null,"summary":"00-0123 response to Keehn Service Corporation concerning 180.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0123.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0123.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0123","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000123.pdf","body":"<<<PAGE 1>>>\n\nTransportatio\nS. Departmen\n400 Seventh Street, S.W.\nWashington, D.C.\n20590\nMAY 1 0 2000\nMr. Richard C. Willard\nRef. No. 00-0123\nPresident\nKeehn Service Corporation\n99 North 11'h Avenue\nCoatesville, Pennsylvania 19320\nDear Mr. Willard:\nThis responds to your letter, dated April 18, 2000, concerning certain record keeping requirements\napplicable to cargo tanks used to transport liquefied compressed gases under the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about the information that will be\nrequired to document hose testing conducted by a Registered Inspector in accordance with\n§ 180.407(h)(4) of the HMR.\nAs currently written, the language related to record keeping in § 180.407(h)(4) is unclear, particularly\nthe reference to the date of the \"original hose assembly test.\" The inclusion of the term \"original\" in this\nparagraph was inadvertent. To comply with the record keeping requirements in this paragraph, a\nRegistered Inspector must note the hose identification number of the hose being tested, the date of the\ntest, and the condition of the hose assembly and piping system tested. We will delete the inadvertent\nreference to an \"original\" hose assembly test in a future rulemaking.\nSection 180.416(b) of the HMR requires operators to assure that each cargo tank delivery hose\nassembly is permanently marked with a unique identification number and maximum working pressure.\nThis marking must be applied by July 1, 2000. In addition, after July 1, 1999, new and repaired hose\nassemblies must be marked with the month and year that they were pressure tested in accordance with\n§§ 178.337-9(b)(7) and 180.416(f). Hose assemblies manufactured or repaired prior to July 1, 1999,\nwill not have this test marking.\nYou are correct that, after July 1, 2000, operators must maintain written records documenting pressure\ntests for new and repaired hose assemblies. The record must include the date of the test, the signature\nof the inspector, the name of the hose owner, the hose identification number, the date of the original\n180.407\n000123\n\n<<<PAGE 2>>>\n\ndelivery hose assembly and test, notes of any defects observed and repairs made, and an indication that\nthe delivery hose assembly passed or failed the tests or inspections. For hose assemblies manufactured\nor repaired prior to July 1, 1999, there will be no date for an original hose assembly test because none\nwas required before this date. For hose assemblies manufactured after July 1, 1999, the date the hose\nassembly was manufactured and pressure tested will be marked on the hose and must be entered on\nthe written record documenting any subsequent pressure test.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact this\noffice.\nSincerely,\nThorn I. Allan\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nKEENN\nGorsku\nSERVICE CORPORATION\n$ 18-0023\n99 NORTH 11th AVENUE • COATESVILLE, PA 1932(\nPHONE: (610) 384-6851\nFAX: (610) 380-0316\nApril 18, 2000\nMr. Edward T. Mazzullo, Director\nUnited States Department of Transportation\nOffice of Hazardous Materials Standards\nResearch and Special Programs Administration\ngram Amition\nWashington, DC\n400 Seventh Street, Southwest\n20590\nRE: Request for Clarification-Hose Testing and Inspection\nDear Mr. Mazzullo,\nMC-330 and 331 compressed gas equipment. We hold valid \"U\" and \"R\" certification stamps and\nKeehn Service Corporation is currently involved with the fabrication, testing, and repair of\nare registered with the Department under CT number 0140.\nIn preparation for the new hose inspection deadline of July 1, 2000, we are making\nmodifications to our external visual (\"V*) and leakage test (\"K\") forms. Under the leakage test\nrequirements as shown in 180.407 (h) (4), we foresee the potential problem of receiving\nserial number marked on the delivery hose or hoses. This will be especially true for the propane\ncustomers equipment brought into our shop for this inspection without the original test date and\nbobtail trucks with hoses mounted on hose reels on the back deck of the truck. Under the current\nregulations as shown in 180.407 (h)(4), if these markings are missing, the hose does not comply\n$180.407(h)(4) After July 1, 2000, Registered Inspectors of specification MC-\n•\n330 and MC331 cargo tanks, and nonspecification cargo tanks authorized under\n§173.315 (k) of this subchapter must visually inspect the delivery hose assembly\nrejection criteria listed in §180.416 (g). Delivery hose assemblies not\nand piping system while the assembly is under leakage test pressure utilizing the\npermanently attached to the cargo tank motor vehicle may be inspected\nseparately from the cargo tank motor vehicle. In addition to a written record of the\nconducting the hose test must note the hose identification number, the\ninspection prepared in accordance with §180.417 (b), the Registered Inspector\nassembly and piping system tested.\ndate of the original hose aşsembly test, and the condition of the hose\nThere does not appear to be any relief from the regulation requiring certain original hose\nas shown in 180.416 (f), which allows for the retesting of a repaired hose, the date of the original\nmanufacturer markings. Even under the new and repaired section for delivery hose assemblies\nhose assembly and test is required.\n\n<<<PAGE 4>>>\n\n§180.416(f)(3) After July 1, 2000, the operator must complete a recora\ninspector, the hose owner, the hose identification number, the date of\ndocumenting the test and inspection, including the date, the signature of the\nrepairs made, and an indication that the delivery hose assembly passed or failed\noriginal delivery hose assembly and test, notes of any defects observed and\nthe tests and inspections.\nmarkings, and the operator or owner cannot provide this information to us from his or her files,\nWhat we are proposing is that in the event we find a hose that does not have the required\nthat we be capable of recertifying the existing hose assembly (if we so choose) by performing the\nfollowing operations:\n1. Perform a visual inspection of the full length of the outside of the hose assembly and\n2. With visual inspection approval, pressure test the hose to 120 percent of hose\nreject any assemblies per the rejection criteria as contained in §180.416(g).\nPermanently mark the tested assembly with the date of this test, the test pressure\nmaximum working pressure (generally extruded into the covering of the hose itself)\nand a new unique identification number for this assembly. A report of this retestin\nis installed with a copy to be retained on file by us as the hose testing company.\nsample attached) would be provided to the owner or lessor of the vehicle on which i\nissemblies. These assemblies are expensive (a new 1\" diameter by 150 foot long propan:\nThis proceedure would allow for the continued use of otherwise good and safe hose\nelivery hose sells for $455.00) and if inspected and tested properly could provide additiona\nyears of safe delivery for our customers.\nreached by telephone at the number shown above or by email at rcwillard@aol.comfor\nPlease advise at your earliest convenience if you find our suggestion plausible. 1 can be\ncomments or questions. Thank you for your help in this matter.\nSincerely,\nDill\nRichard C. Willard\nPresident\nAttachment\nMsword DOT-letter-request for ruling-4-00.doc\n•\n\n<<<PAGE 5>>>\n\nKeehn Service Corporation\nHose Test Report\nCustomer:\nCustomer Location (District ) :\nTruck unit number:\nMake of hose :\nOriginal Hose Information\nDiameter of hose :\nLength of hose:\nPrevious test I.D. or Keehn S.O. number :\nOriginal hose test date:\nOriginal hose test pressure :\nNew Keehn Identification Number :\nNew Test Information\nNew Test Date :\nMonth:\nDay:\nYear:\nTest Pressure :\n(120% of maximum work pressure- 350 Rated hose=420 Lbs.test)\nInspection Criteria\nPASS\nFAIL\n1- Condition Of Hose Assembly:\n2- Damage to hose cover that exposes the reinforcement.\n3- Wire braid reinforcement has been kinked or flattened so as to\npermanently deform the wire braid\n4- Soft spots when not under pressure, bulging under pressure\nor loose outer covering.\n5- Loose or missing bolts or fasteners on bolted hose coupling\nassemblies.\nInspector Print:\nInspector Signature :","truncated":false,"body_characters":8317}