{"operation":"document","citation":"00-0338","title":"C&R Fleet Services, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-04-30","effective_on":null,"summary":"00-0338 response to C&R Fleet Services, Inc. concerning 180.416.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0338.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0338.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0338","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000338.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nWashington, D.C. 20590\n400 Seventh St., S.W.\nResearch and\nSpecial Programs\nAdministration\nAPR 3 0 2001\nMs. Michelle Cannon\nC&R Fleet Services, Inc.\nRef. No. 00-0338\n353 O'Dell Road\nGriffin, Georgia 30224\nDear Ms. Cannon:\nThis responds to your request for interpretation, dated December 4, 2000, concerning rejection\ncriteria specified in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for\nhoses on cargo tanks used for the transportation of liquefied compressed gases. Specifically, you\nask if a hose that has sustained minor damage to the outer hose covering must be removed from\nservice. You provided samples of two hoses to illustrate your question.\nSection 180.416(g)(1) of the HMR establishes rejection criteria for hoses on cargo tanks used to\ntransport liquefied compressed gases. Paragraph (g)(1)(i) requires a hose with damage to the\nhose cover that exposes the reinforcement to be removed from service. In the sample of the\ndamaged hose you provided, hose reinforcement is accomplished by means of a nylon-type\nmaterial interwoven in the hose assembly and extending to the outer edge of the rubber outer\nhose covering. The damage to the sample hose exposed the nylon reinforcement. In this case,\nthe hose would need to be repaired and tested prior to use.\nThe second sample hose you provided has several layers of protection between the rubber outer\nhose covering and the nylon reinforcement. This type of hose may continue to be used with\nminor damage to the outer hose covering, provided the nylon reinforcement layer is not exposed.\nA hose that has sustained damage sufficient to penetrate the outer layers and expose the nylon\nreinforcement must be repaired and tested prior to use.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nThi\nis. Call\n•cim\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nGorsky\n3180.41629()\nCargo Tank\n00-0338\nDecember 4, 2000\nHazardous Materials Division\nResearch and Special Programs Administration\nDepartment of Transportation\nWashington, DC 20590-001\nC & R Fleet Services, Inc\n353 O'Dell Road\nGriffin, Georgia 30224\nSubject: Request for Interpretation of Hazardous Material Regulation 180.412(g)(i)\nSir:\nThis letter is to request an interpretation of the rejection criteria for hoses involved in the\ntransportation of liquefied compressed gases. Specifically, paragraph (g) (i) of section\n180.412, \"Damage to the hose cover that exposes the reinforcement.\"\nHoses used in the transfer of liquefied compressed gasses are made up of many layers of\nreinforced material. In the past, because of lack of specific pass fail criteria, the industry\nhas assumed that minor damage to the outer covering that exposes only one or two of the\nreinforcement layers was not a failing condition because, the structural integrity of the\nhose is not compromised. In fact, in many instances, the hose will pass a pressure test to\n120% MAWP with several layers of reinforcement exposed.\nThese hoses are exposed to a great deal of rubbing as the result of vibration during the\ntransfer of product and frequently the first layer of reinforcement, only millimeters from\nthe surface of the hose, may be exposed after only one or two uses. In this case, the\nstructural integrity of the hose is not compromised but the literal interpretation of Sec\n180.416 (g)(i) is that the hose is out of service and must be replaced.\nPlease advise us as to how much of the hose reinforcement may be exposed before the\nhose must be removed from service.\nIf you require additional information please feel free to call (770) 412-8211.\nThank You,\n\n<<<PAGE 3>>>\n\nB..i\n•\n2.., 7\nGorsky, Susan\nFrom:\nSent:\nShelton, Daniel <FHWAS P\nwei.Btetton@fhwa.dot.gov]\nSubject:\nTo:\nGorsky, Susan <RSPA>\nTuesday, December 05, 2000 1:46 AM\nFwd: Request for Interprolation\nENCLOSURE\nRequest for Ruking.doc\nour discussions\nSusan, attached de 4 request for interpretation resulting from\nLast week at a cargo tank seminar in charlotly, forth Carolina.\nBased on the feedback from the participants, sidely rubbing the hose through\nthe first layer of rubber reinforcement does hot compromise the integrity of\nreinforcement and then up to twelve layers of rubber reinforement on the\nThese hoses are constructed of an inner linner, then a wire\noutside.\nIf you need additional information contact le or Michelle at the company.\nShe left her phone number and address.\nThanks again.\nCarish\n:\n\n<<<PAGE 4>>>\n\n. Anthony Reid\nRI - CT 7588","truncated":false,"body_characters":4613}