{"operation":"document","citation":"02-0290","title":"Raymond Schaffer — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-07-30","effective_on":null,"summary":"02-0290 concerning 180.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0290.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0290.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0290","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020290.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nResearch and\nWashington, D.C. 20590\nJUL 30 2003\nMr. Raymond Schaffer\n4477 Sheila Street\nRef. No. 02-0290\nLos Angeles, CA 90023\nDear Mr. Schaffer:\nThis is in response to your August 26, 2002 letter concerning the requirements for a turntable assembly\non a DOT Specification cargo tank motor vehicle under the Hazardous Materials Regulations (HMR;\n49 CFR Parts 171-180). Specifically, you ask if the turntable assembly, as depicted in the\nphotographs you provided, must be removed to fulfill either the visual inspection or pressure test\nrequired by § 180.407(d)(2)(viii) and (g)(1)(iii), respectively.\nTurntable assemblies serve the same function as an upper coupler and must be removed from the cargo\ntank for inspection in accordance with § 180.407(d)(2) (vili) and (g)(1)(ill), respectively. The primary\npurpose for this inspection is to inspect for corroded and/or abraded areas of the cargo tank which may\nrequire thickness testing. Upper couplers are normally attached to the tank using bolts and are\ndesigned to be removed and replaced, if necessary. Turntables are typically attached to the tank by\nmeans of welding and are not designed to be removed from the cargo tank without cutting. Turntable\nassemblies serve as the front support for the trailer in lieu of dolly legs and they normally stay attached\nto the cargo tank for the life of the tank, very similar to the rear suspension components of the cargo\nFrom the photographs you provided it does not appear that the turntable can be removed from the tank\nwithout cutting and welding. Further, removing the turntable would not facilitate a more thorough\nexternal visual inspection of the area of the cargo tank directly above the turntable. Therefore, the\nturntable assembly may remain on the cargo tank under the following conditions:\nThe turntable assembly must allow a complete external visual inspection of the area of\nthe cargo tank that is directly above the turntable. The visual inspection must be as\neffective as performing an external visual inspection of this area if the turntable were to\nbe removed.\n2.\nThe external visual inspection and pressure test must be conducted by directly viewing\nthe tank; therefore, the use of a device that creates an image of the tank (i.e., mirrors,\ncameras, or fiber optics) is prohibited.\n180.407\n020290\n\n<<<PAGE 2>>>\n\n•\n•\nAll major appurtenances and structural attachments on the cargo tank that can be\ninspected without dismantling the turntable assembly must be inspected for any\ncorrosion or damage that might prevent safe operation (§ 180.407(d)(2)(viii)).\nAreas covered by the turntable assembly must be inspected for corroded and abraded\nareas, dents, distortions, defects in welds, and any other condition that may render the\ncargo tank unsafe for transportation service (§ 180.407(g) (1)(iii)).\nIf the area above the turntable cannot be observed and the turntable cannot be removed without cutting\nand welding then the tank must be internally inspected and those areas of the tank above the turntable\nmust be thickness tested in accordance with § 180.407(i)(2). The number of thickness test points is\ndependent upon the area of the tank shell above the turntable that cannot be visually inspected. For\ncopy of the thickness test report identifying the areas tested and the measurements recorded for each\neach square foot of tank shell surface area above the turntable you must perform six thickness tests. A\ntest location must be maintained with the external visual inspection report or the pressure test report, as\nappropriate, and a copy of this report must be provided to the owner and operator, if not the owner, of\nthe cargo tank.\nThe photographs you provided indicate that this cargo tank and turntable assembly could fulfill the\ncriteria outlined above. However, if the cargo tank is not equipped with a manhole, the turntable\nassembly must be removed from the cargo tank in order to meet the visual inspection and/or pressure\ntest requirements.\nSincerely,\nSusa Orato\nSusan Gorsky\n• Senior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n::.\n*%.\n\n<<<PAGE 3>>>\n\nWELD-IT COMPANY\nAugust 26. 2002\n177 SHELA STREET * LOS ANGELES. CALFORNIA Y\n42\\31 263 7520\nU.S. Department of Transportation\n323-263-7524\nFAX 1213/ 201-4073\nHazardous Material: Division\nPederal Mour Currier Safety Administration\nJohnsen\n400 7\" Street, SW\nWashington, DC 204g0).\n§180.401\nAun: Mr. Daniel G. Stetton\nCargo Tanks\nHazardous Materials Program Specialin\nPh #(202) 366-0476\nFax #202) 366-7908\n02-0290\nSubject: Pressure test af cargo tanks Ref: No.01-0203\nMeno from Thomas G. Allan, Senior\nTransportation Regutatioss Spocialist\nTo: William A. Orade\nChief of Hazardous Materials Division dared August 16, 2001\nDear Str:\nPlease excuse the delay of our reply to the phone conversation between yourself and me.\ntanker.\nIt took sometime to get the pictures you asked for on the North Wost fou (4) ande super\nUnlike a semi initer with a fult upper coupler s\" wheel plate that prevents inspectors\nfrom observing the bottom of a cargo tank during pressure test, two (2) axle West Coast\nFull trailer and the majority of four (4) asle suppet trailers this is not the case We have\nenclosed pictures of both types of units.\nAs you can ser with both types of units you can see the bottom of cargo tank tau the\nopening of the roller wheel and tumtable upper sub-frame. While there are some\nmanufactures that use a fill plate between upper and loser sub-frame this seem to be on\nthe four (4) axle super tanker only. In this case the inspection facility would have 10\nremove the turinble assembly the same as u semi 5\" wheel plate. On those units that do\nair tank or some other hardware to make inspection. -This is certainly easier and more\nnot need the turntable removed it may be necessary for inspection facility to remove an\ncost effective than removing the complete turtable asserably.\n\n<<<PAGE 4>>>\n\n..\nAs we discussed in our phone conversation when a turntable assembly and a 5\"\" wheel\nand replacement\nplate are removed for testing they should be marked with dated and inspector after test\nUnlike a semi trailer, which has land gear to set the cargo tank on a full trailer or super\nputting 20,000 Ibs of water on the trailer and putting an inspector under the front of the\ntanker is harder to support without the front turntable. We have some problem with\nunit.\nWe are asking that Federal Motor Carrier reconsider it's position and allow inspection\nfacilities not to remove the turntable when the bottom of the cargo tank can be inspected\nduring pressure testing. Those units that cannot meet this requirement will have to have\nbe a cost benefit to our customer and safer operation for our employee's.\nturntable removed just like a semi trailer upper s\" wheel coupler plate. This option will\nassistance, please call.\nYour earliest consideration will be gratefully appreciated. If we may be of any\nSincerely,\nRaymond Schaffer\n-r=h","truncated":false,"body_characters":7014}