Guidanceguidance
04-0005
Arbonite — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department of Transportation 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs Administration MAY 11 2004 Mr. Lee K. Robinson 3826 Old Easton Road Arbonite Ref. No. 04-0005 Doylestown, PA 18901 Dear Mr. Robinson: This responds to your December 22, 2003, letter requesting clarification on inspection of non- DOT specification 407 and 412 cargo tanks constructed from glass fiber reinforced plastics (GFRP) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether these cargo tanks are subject to the "L" lining inspection under § 180.407(f) and the internal visual inspection "P" under § 180.407(e). Cargo tanks constructed from GFRP are authorized only by DOT exemption. These DOT exemptions, e.g., DOT E-11903 and DOT E-12516 enclosed, specifically waive Special Provisions B15 and B23 in the HMR. These cargo tanks do not have a lining and, therefore, are subject to the internal visual inspection requirements of § 180.407(e). not subject to the lining inspection requirements of § 180.407(f). However, these cargo tanks are I hope this answers your inquiry. John A. Chief, Standards Development Gale Office of Hazardous Materials Standards Enclosures 180.409 040005#
Page 2Boothe arbonite §180.407 A DIVISION OF P & R INDUSTRIES, INC. 3826 OLD EASTON ROAD Testing DOYLESTOWN, PA 18901 P.O. BOX 888 215-345-1251 (FAX) 215-348-2950 04-0005 December 22, 2003 Research and Special Programs Administration U.S. Department of Transportation 400 Seventh St. S. W. Washington, D.C. 20590 Attention: Ms. Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Dear Ms. Gorsky, vehicles DOT 407 and DOT 412 that are constructed from glass fiber reinforced I am writing with reference to (GFRG) non-DOT specification cargo tank motor plastics. Do these tanks need the "L" lining inspection? If the answer is yes where performed per regulation 180.407(e)? Also, on the same tanks as listed above, is the internal visual inspection "p" Thanks very much for your assistance. I will look forward to hearing from you as quickly as possible. Sincerely, dek Fabum Lee K. Robinson Sales Manager APPLICATORS OF PROTECTIVE COATINGS AND LININGS#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.