{"operation":"document","citation":"00-0382","title":"Federal Motor Carrier Safety Administration — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-04-06","effective_on":null,"summary":"00-0382 response to Federal Motor Carrier Safety Administration concerning 180.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0382.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0382.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0382","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000382.pdf","body":"<<<PAGE 1>>>\n\nMemorandum\nU.S. Department\nof Transportation\nSpecial Programs\nResearch and\nAdministration\nDate:\nAPR - 6 2000\nReply to Attn. of: Gorsky, x69532\nsubject: Request for Interpretation Clan\nThoma\nFrom:\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\nTo: Stephen E. Barber\nActing Director of Enforcement and Compliance\nFederal Motor Carrier Safety Administration\nThis responds to your request for an interpretation, dated March 27, 2000, of certain record keeping\nrèquirements applicable to cargo tanks used to transport liquefied compressed gases under the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about the..\ninformation that will be required to document hose testing conducted by a Registered Inspector in\naccordance with § 180.407(h)(4) of the HMR.\nYou are correct that, as currently written, the language related to record keeping in § 180.407(h)(4) is\nunclear, particularly the reference to the date of the \"original hose assembly test.\" The inclusion of the\nterm \"original\" in this paragraph was inadvertent. To comply with the record keeping requirements in\nthis paragraph, a Registered Inspector must note the hose identification number of the hose being\ntested, the date of the test, and the condition of the hose assembly and piping system tested. We will\ndelete the inadvertent reference to an \"original\" hose assembly test in a future rulemaking.\nYour understanding of the hose marking requirements is correct. Section 180.416(b) of the HMR\nrequires operators to assure that each cargo tank delivery hose assembly is permanently marked with a\nunique identification number and maximum working pressure. This marking must be applied by\nJuly 1, 2000. In addition, after July 1, 1999, new and repaired hose assemblies must be marked with\nthe month and year that they were pressure tested in accordance with §§ 178.337-9(b)(7) and\n180.416(f). Hose assemblies manufactured or repaired prior to July 1, 1999, will not have this test\nmarking.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact this\noffice.\n\n<<<PAGE 2>>>\n\nU.S. Department\nMemorandum\nof Transportation\nSafety Administration\nFederal Motor Carrier\nGorsky\n$180.407\n00-0089\nSubject: Request for Interpretation\nDate:\nMAR 2 7 2000\nFrom: Acting Director of Enforcement\nReply to\n& Compliance\nAttn. of:\nTo:\nMr. Ed Mazzullo\nDirector, Office of Hazardous\nMaterials Standards\nResearch and Special Programs Administration\nThe Federal Motor Carrier Safety Administration(FMCSA) is moving forward to ensure\ncompliance with rules promulgated under Docket HM-225 A (Revision to Regulations\nGoverning Transportation and Unloading of Liquefied Compressed Gases). A question has been\nforwarded to us requesting a clarification of 180.407(h)(4). The issues and concerns are\nexplained below.\nThe last sentence in 180.407(h)(4) reads as follows:\n\"In addition to a written record of the inspection prepared in accordance with\n§180.417(b), the Registered Inspector conducting the hose test must note the hose\nidentification number, the date of the original hose assembly test, and the condition\nof the hose assembly and piping system tested.\nIt is our understanding the meaning of \"original hose assembly test\" is the test identified in\n178.337-9(b)(7).\nPrior to June 1, 1999 there was no requirement for a hose assembler to mark the hose with the\nmonth and year of its original hose assembly test. What information, if any, will be required of\nthe Register Inspector to comply with 180.407(h)(4) when inspecting hoses assembled prior to\nJune 1, 1999?\nStephen E. Barber","truncated":false,"body_characters":3666}