Goodall Rubber Company — Hazardous Materials Safety Interpretation

Page 1of Transportatior U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Hazardous Materials Safety Pipeline and Administration APR 20 2006 Mr. Brad Ferstan Ref. No. 05-0195 3525 Labore Road Goodall Rubber Company Vadnais Heights, MN 55110 Dear Mr. Ferstan: This responds to your letter regarding the use of rubber hose fittings on MC-331 cargo tanks in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- made to NPTF thread specification would be acceptable to use on MC-331 cargo tanks, 180). Specifically, you asked if your understanding is correct that rubber hose fittings provided they meet all applicable requirements of § 178.337-9. For an MC-331 cargo tank, pipe joints must be threaded, welded, or flanged. If threaded pipe is used, the pipe and fittings must be "Schedule 80" weight or heavier, except for sacrificial devices. Malleable metal, stainless steel, or ductile iron must be used in the construction of primary valve body parts and fittings used in liquid filling or vapor equalization. As a result, a rubber fitting cannot be used in any connection on the cargo tank that involves either filling the tank or any system on the tank that provides for vapor equalization. Stainless steel may be used for internal components such as shutoff discs and springs except where incompatible with the lading to be transported. Where copper tubing is permitted joints must be brazed or be of equally strong metal union type. The melting point of the brazing material may not be lower than 538°C (1,000°F). The method of joining tubing may not reduce the strength of the tubing. (See § 178.337-9 (b) (2)). The hose identification, inspection, and testing requirements for hoses on cargo tanks requirements apply to delivery hoses and hose assemblies only. A rubber hose used as a used to transport liquefied compressed gases are in §180.416 of the HMR. These flexible connector in the piping system of a cargo tank is not a delivery hose. Thus, such rubber 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 rubber flexible connectors must be 178.337-9 050195#

Page 2inspected and tested in accordance with requirements applicable to piping systems in § 180.416 I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, John A. Gale Chief, Standards Development Office of Hazardous Materials Standards#

Page 3To: Page 1 of 1 2005-08-12 18:47:35 (GMT) 6513053089 From: Brad Ferstan Engrum 8178.337-4 FAX COVER SHEET Cargo Tanks 05-0195 TO COMPANY FAX NUMBER 12023663012 FROM Brad Ferstan DATE 2005-08-12 18:54:09 GMT RE ATTN: Edward Mazzullo COVER MESSAGE Edward, regarding the hose I was told to contact you regarding a question I had connection on an MC331 cargo tank, specifically section 178.337-9, part b - piping, valves, hose, and fittings. . Can I please get a written response from you regarding my question? It can be faxed to the number below or e-mail to me at brad.ferstan@trelleborg.com. My question is whether paragraph 2 of the previously mentioned section applies to rubber hose fittings? It has been my hose fittings, or couplings, made to the NPTF thread understanding that rubber specification would be acceptable provided that they meet all other paragraphs 3 and 7. requirements such as Can you please help me out? Thank you for your assistance. Brad Ferstan 3525 Labore 1 Goodall Rubber Company - Minneapolis/St. Paul Branch Sales Manager Vadnais Heyh PH: 612-382-2519 MN 55110 Fax: 651-305-3089 11003313349 × 223 GET FREE ONLINE FAX DELIVERY FROM •FAX WWW.EFAX.COM#