{"operation":"document","citation":"00-0181","title":"Samson Tug and Barge Company, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-09-25","effective_on":null,"summary":"00-0181 response to Samson Tug and Barge Company, Inc. concerning 176.76.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0181.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0181.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0181","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000181.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nWashington, D.C. 20590\n400 Seventh St., S.W.\nResearch and\nSpecial Programs\nAdministration\nSEP 2 5 2000\nMr. Al Snelling\nRef. No: 00-0181\nSamson Tug and Barge Company, Inc.\nP.O. Box 559\nSitka, Alaska 99835\nDear Mr. Snelling:\nThis is in response to your letter of June 13, 2000, requesting information concerning the transport of\npropane in an MC-330 / MC 331 cargo tank on a barge under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:\nQ1. May propane be transported on a deck cargo barge in an MC 330/331 cargo tank either on a\nCFC cargo platform or in a roll on - roll off (ro-ro) fashion?\nWith respect to ro-ro transport, § 176.76(b) requires transport vehicles containing hazardous materials\nto be carried only on trailership, trainship, ferry vessel or carfloat as those terms are defined in the\nHMR (refer to § 171.8 for definitions). Depending on the type of service (route) in which it is engaged,\na deck cargo barge suitable for that type of service could transport an MC 330/331 cargo tank as ro-\nro cargo.\nWe assume that your reference to CFC platform was meant to be a reference to a container frame or\nflatrack that meets the provisions of the International Convention for Safe Containers (CSC\nConvention). An MC 330/331 cargo tank that is adequately secured on a container such as a flatrack\nthat meets the provisions of 49 CFR 450 to 453 may also be transported on a deck cargo barge\nprovided the barge is suitable for the type of service (route) in which it is engaged. Note that if the\ncargo tank is altered such that it no longer meets the definition of \"cargo tank\" (e.g., by removal of the\npressure vessel portion of the cargo tank from the vehicle or trailer chassis), the foregoing does not\napply. In a situation such as this where the pressure vessel is removed from its trailer chassis it would\ncease to meet the definition of a cargo tank and could only be used if authorized under a DOT\nexemption or remanufactured to an authorized DOT specification.\n\n<<<PAGE 2>>>\n\n•\n-2-\nQ2. May propane be carried on a deck cargo barge in any fashion other than in a DOT 51 portable\ntank?\nIn addition to the manner discussed in the answer to question 1 above, propane also may be\ntransported in certain non-bulk packagings (DOT specification cylinders) in accordance with\n§ 173.304 and otherwise in accordance with 49 CFR 176.\nI hope this information is helpful.\nSincerely,\nDamn Fos ess\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\ncc: USCG -HQ\n\n<<<PAGE 3>>>\n\n06/13/2000\n09:09\n9077476568\nPAGE 01/01\nLavalle\n+15736385176.76\n00-016\n• SAMSON TUG & BARGE COMPANY, INC.\nPhone (907) 747-8796 - Fax (907) 747-6560 - P.O.Box 559 - Sitka, Alaska 99835\nFAX TRANSMITTAL\nDate: JuNE' 00\nTime: 1010 ABsT Fax Number: d0a 3l6 3012\nED muzzullo\n-RspA\nIo: DOT O4ms\nLocation: WDS4. DE\nPages:_L\nREF: CARRIAGE OF PROPANE IN 330/331 TANKAGE ON DECK BARGES\n1. May propane contained in a 330/331 approved tank (transportation vehicle) be\nloaded on a deck cargo barge either on a CFC cargo platform or in a ro-ro fashion\nand transported upon the high seas?\n:\n2. May propane be carried on a deck cargo barge in any fashion otber than ia a\nDOTS1 approved tank?\nWe are in the Alaska trade, desiring to be legal and safe in all matters of\ntransportation and time is of the essence in this issue. The \"propane tank\" issue is a\n•\nhot item in the Northwest this summer and we have spoken with Mt. Charles\nHoschmann, this date on this matter and he has recommended we forward this\nrequest.\nWe understand the time restraints you are working under, however we would\nrequest your immediate response to our questions, as the Alaskan sumer can be a\nvery short one. I a sincerely\nA:\nAL SNELLING\n:","truncated":false,"body_characters":3828}