{"operation":"document","citation":"00-0189","title":"Specialized Transport Repair — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-01-09","effective_on":null,"summary":"00-0189 response to Specialized Transport Repair concerning 180.403.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0189.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0189.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0189","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000189.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nJAN - 9 2001\nWashington, D.C.\nSpecial Programs\nResearch and\nAdministration\nMr. John P. McGavis\nRef. No. 00-0189\n100 Commerce Drive\nSpecialized Transport Repair\nBuffalo, NY 14218\nDear Mr. McGavis:\nThis responds to your letter requesting clarification of the\nmodification, repair, and certification requirements of MC 307\nand DOT 407 cargo tank motor vehicles under the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180).\nSpecifically,\nmanway covers would be considered a repair, rather than a\nyou inquire whether the installation of larger nozzles into\nmodification and, therefore, would not require certification by a\nDesign Certifying Engineer.\nYou state that the 1998 National\nof a repair as \"the installation of new nozzles or openings of\nBoard Inspection Code, in Appendix 6 (b) (9), describes one example\nsuch\na size that reinforcement is not a consideration.\"\nThe installation of new nozzles in a manhole cover that differ in\nsize or design from the originally installed nozzles would be\nconsidered a design change and categorized as a modification, not\na repair under the HMR.\nA design type change requires approval\nand certification by a Design Certifying Engineer as specified in\n$ 180.413 of the HMR.\nHI. Re deraned any\nAs defined in § 180.403, a \"modification\"\nmeans\ncargo tank or cargo tank motor vehicle that affects its\nany change to the original design and construction of a\nstructural integrity or lading retention capability. Excluded\nare the replacement of components of similar design\nand of the\nsame size.\nI trust this satisfies your inquiry. Please contact us if we can\nbe of further assistance.\n• Sincerely,\nHotte z michele\nHattie I. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n180.403\n000189\n\n<<<PAGE 2>>>\n\n•\nGOT\n100 Commerce Drive\nBuffalo, NY 14218\nSPECIALIZED TRANSPORT\nPhone (716) 827-8265\nREPAIR Inc.\nFax (716) 827-7231\nStevens\nJune 27, 2000\nFederal Motor Carrier Safety Administration\nRef. No. 00-0157\n5180.403\nResearch and Special Programs Administration\nHazardous Materials Division\n00-0189\n4007° St. SW\nWashington, DC 20590\nMr. Daniel Shelton,\nThis letter is a continuation of our dialogue regarding the addition of nozzles into the\nmace yater 620-0, 5307 athl this would ge considered am recenton an a such would\nnanufacturer's certificate. t\nconstruction, repair, and alteration of these tanks would follow ASME and National Board\nstandards. The National Board Code clearly states in Appendix 6[B]|?] as an example of a\nrepair (as opposed to alterations):\n\"installation of new nozzles or openings of such a size that reinforcement is not a\nconsideration (for example, the installation of a 3 NPS nozzle to a shell or head of 3/8 inch\nor less in thickness or the addition of a 2 NPS nozzle to a shell or head of any thickness).\"\n(Per ASME UG-36[c][3] [a] this nozzle does not require reinforcement.)\nThe example National Board chose is exactly the same as the installation we have been\nbe called for. Also the associated documents would not be required\nliscussing. If in fact this is a \"repair\", the role of the Design Certifying Engineer would not\n1. Can installation of 3\" nozzles be treated as a \"repair\", considering that this is a specifc\nOur questions are:\n2. I so, cola Design raging Beiner services and related documentation become\nThank you,\nTohn P. McGavis\nEnc: National Board Appendix 6 [B][9]","truncated":false,"body_characters":3439}