C&R Fleet Services, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh St., S.W. Research and Special Programs Administration APR 3 0 2001 Ms. Michelle Cannon C&R Fleet Services, Inc. Ref. No. 00-0338 353 O'Dell Road Griffin, Georgia 30224 Dear Ms. Cannon: This responds to your request for interpretation, dated December 4, 2000, concerning rejection criteria specified in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for hoses on cargo tanks used for the transportation of liquefied compressed gases. Specifically, you ask if a hose that has sustained minor damage to the outer hose covering must be removed from service. You provided samples of two hoses to illustrate your question. Section 180.416(g)(1) of the HMR establishes rejection criteria for hoses on cargo tanks used to transport liquefied compressed gases. Paragraph (g)(1)(i) requires a hose with damage to the hose cover that exposes the reinforcement to be removed from service. In the sample of the damaged hose you provided, hose reinforcement is accomplished by means of a nylon-type material interwoven in the hose assembly and extending to the outer edge of the rubber outer hose covering. The damage to the sample hose exposed the nylon reinforcement. In this case, the hose would need to be repaired and tested prior to use. The second sample hose you provided has several layers of protection between the rubber outer hose covering and the nylon reinforcement. This type of hose may continue to be used with minor damage to the outer hose covering, provided the nylon reinforcement layer is not exposed. A hose that has sustained damage sufficient to penetrate the outer layers and expose the nylon reinforcement must be repaired and tested prior to use. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Thi is. Call •cim Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 2Gorsky 3180.41629() Cargo Tank 00-0338 December 4, 2000 Hazardous Materials Division Research and Special Programs Administration Department of Transportation Washington, DC 20590-001 C & R Fleet Services, Inc 353 O'Dell Road Griffin, Georgia 30224 Subject: Request for Interpretation of Hazardous Material Regulation 180.412(g)(i) Sir: This letter is to request an interpretation of the rejection criteria for hoses involved in the transportation of liquefied compressed gases. Specifically, paragraph (g) (i) of section 180.412, "Damage to the hose cover that exposes the reinforcement." Hoses used in the transfer of liquefied compressed gasses are made up of many layers of reinforced material. In the past, because of lack of specific pass fail criteria, the industry has assumed that minor damage to the outer covering that exposes only one or two of the reinforcement layers was not a failing condition because, the structural integrity of the hose is not compromised. In fact, in many instances, the hose will pass a pressure test to 120% MAWP with several layers of reinforcement exposed. These hoses are exposed to a great deal of rubbing as the result of vibration during the transfer of product and frequently the first layer of reinforcement, only millimeters from the surface of the hose, may be exposed after only one or two uses. In this case, the structural integrity of the hose is not compromised but the literal interpretation of Sec 180.416 (g)(i) is that the hose is out of service and must be replaced. Please advise us as to how much of the hose reinforcement may be exposed before the hose must be removed from service. If you require additional information please feel free to call (770) 412-8211. Thank You,#

Page 3B..i • 2.., 7 Gorsky, Susan From: Sent: Shelton, Daniel <FHWAS P wei.Btetton@fhwa.dot.gov] Subject: To: Gorsky, Susan <RSPA> Tuesday, December 05, 2000 1:46 AM Fwd: Request for Interprolation ENCLOSURE Request for Ruking.doc our discussions Susan, attached de 4 request for interpretation resulting from Last week at a cargo tank seminar in charlotly, forth Carolina. Based on the feedback from the participants, sidely rubbing the hose through the first layer of rubber reinforcement does hot compromise the integrity of reinforcement and then up to twelve layers of rubber reinforement on the These hoses are constructed of an inner linner, then a wire outside. If you need additional information contact le or Michelle at the company. She left her phone number and address. Thanks again. Carish :#

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