Gas Service and Supply, Co — Hazardous Materials Safety Interpretation

Page 1400 Seventh St., S.W. Washington, D.C. 20590 Research and Administration Special Program: JUN 2 0 2001 Mr. Don Lampshire Ref. No. 01-0154 396 Swan Lake Roac jas Service and Supply, Co Bossier City, Louisiana 71111 Dear Mr. Lampshire: This responds to your June 15, 2001 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hoses on cargo tanks: Specifically, you ask if hose marking and periodic inspection and testing requirements apply to stainless steel flexible hoses on cargo tanks used to transport liquefied compressed gases. The hose identification, inspection, and testing requirements for hoses on cargo tanks used to delivery hoses and hose assemblies only. A stainless steel hose used as a flexible connector in transport liquefied compressed gases are in § 180.416 of the HMR. These requirements apply to the piping system of a cargo tank is not a delivery hose. Thus, such stainless steel flexible connectors need not be marked with a unique identifier and are not subject to the periodic inspection, testing, and recordkeeping requirements applicable to delivery hose assemblies in § 180.416. Note, however, that stainless steel flexible connectors must be inspected and tested in accordance with requirements applicable to piping systems in § 180.416. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 180.416 010154#

Page 2Page 1 of 1 Gorsky, Susan From: GSSPROVERS@aol.com Sent: Friday, June 15, 2001 4:49 PM To: susan.gorsky@rspa.dot.gov Subject: Stainless Steel Flexible Hose Dear Susan: Please clarify the use of stainless steel flexible hoses in applications other than a delivery hose on MC-330, MC-331 & non-specification cargo tanks. the information? Do these stainless steel hoses require an identification Do the stainless steel hoses require testing, dates, and record retention of tag? An interpretation on this matter would be greatly appreciated. Sincerely, Don Lampshire 3396 Swan Lake Road Gas Service & Supply, Co. Bossier City, LA 71111 (318) 747-3425 Fax (318) 742-5881 Phone gssprovers@aol.com 6/18/01#