Guidanceguidance
04-0250
FMC Corporation — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1Or on orion Washington, D.C. 20590 400 Seventh St., S.W. Research anc Special Programs Administration NOV 9 2004 Mr. Michael Jones Ref. No.: 04-0250 FMC Corporation Senior Packaging Engineering APG Operations 119 Roselane Terrace Syracuse, N! 13219 Dear Mr. Jories: This is in response to your November 5, 2004 letter requesting clarification regarding the requalification requirements for DOT 57 portable tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if periodic thickness testing is required for DOT 57 portable tanks. The answer is no. The requalification requirements for DOT 57 portable tanks are found in Part 180, Subpart G. Section 180.605(c)(3) specifies that DOT 57 portable tanks must receive a periodic inspection and pressure test at least once every 2.5 years. The inspection and pressure test requirements are specified in § 180.605(g) and (h)(1), respectively. I hope this in formation is helpful. Please contact us if you require additional assistance. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 180.605 040250#
Page 2satterthwaite $180.605 October 18, 2004 Retesting Portable tank, 04-0250 FMC Agricultural Products 119 Roselane Terrace Syracuse, NY 13219 U.S. Department of Transportation Office of Hazardous Materials Standards Research and Special Programs Administration 400 7" Street, S.W. Washington, DC 20590-0001 Attn: Mr. Edward Mazzullo Mr Mazzullo, This is a request for clarification of sections 173.32 and 180.352 of the U.S. Hazardous Materials Regulations (HMR) contained in Title 49 of the U.S. Code of Federal Regulations (49 CFR). In specific I am requesting clarification around the periodic retesting requirements for DOT 57 tanks? It is my understanding that every 2-1/2 years all IBCs and DOT 57 portable containers must pass am requesting is if the DOT 57 containers are required to be "Thickness Tested" or are they an external visual inspection in addition to a 20kPa (3 psig) air pressure test. The clarification I exempt from this requirement as described in 173.32 3 (c)? Sincerely, Mical frea Michael Jones Senior Packaging Engineer FMC Agricultural Products Michael_jones@fmc.com#
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