{"operation":"document","citation":"05-0200","title":"Mr. Ed Mansell — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-04-11","effective_on":null,"summary":"05-0200 concerning 178.337.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0200.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0200.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0200","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050200.pdf","body":"<<<PAGE 1>>>\n\nOr asporation\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nHazardous Materials Safety\nPipeline and\nAdministration\nAPR 11 2006\nMr. Ed Mansell\nP.O. Box 310\nRef. No. 05-0200\n4825 E. Kearney\nSpringfield, MO 65801\nDear Mr. Mansell:\nThis responds to your August 18, 2005 letter requesting clarification on accident damage\nprotection requirements for MC 331 cargo tanks under the Hazardous Materials\nRegulations (HMR; 49 CPR Parts 171-180).\nSection 178.337-10(a) requires all valves, fittings, pressure relief devices, and other\naccessories to the tank proper to be protected against such damage as could be caused by\ncollision with other vehicles or objects, jack-knifing and overturning. In addition,\npressure relief vales must be protected so that in the event of overturn of the vehicle onto\na hard surface, the valve will continue to function.\nSection 178.337-10(b) requires protective devices or housing to be designed to withstand\nsiled vating lading dising a say to tore the weigh a terabase on taints when.\nstrength of the material to be used, without damage to the fittings protected, and must be\nmade of metal at least 3/16-inch thick.\nYour questions are paraphrased and answered as follows:\nQ1. If there is a shear section in the valves on an MC-331 tank, is accident damage\nprotection required per §178.337-10(b)?\nAl. Yes.\nQ2. If shear sections are provided for the valving and piping, must the accident damage\nprotection conform to $178.337-10(b)?\nA2. Yes.\n178.337-10\n050200\n\n<<<PAGE 2>>>\n\nQ3. If shear sections are not provided for the valving and piping, is accident damage\nprotection required per §178.337-10(b)?\nA3. Yes.\nQ4. Are the accident damage protection requirements for MC 331 cargo tanks being\nevaluated for consistency with the requirements for DOT-406, DOT-407, and DOT-412\ncargo tanks?\nA4. At this time, we are not considering modification to the accident damage protection\nrequirements for MC 331 cargo tanks. You may petition for a rule change if you believe\nthat modification should be considered. Procedures for submitting a petition for\nrulemaking are in 49 CFR 106.95.\nI hope this answers your inquiry.\nChief, Standards Developmen\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nBoathe\nFrom: Ed Mansell\n$178.331-10\n4825 E. Kearney\nP.O. Box 310\nThursday, August 18, 2005\nAccident Damage Protechn er:\n178337-10ADP\nSpringfield, MO 65801\nTo:\nOffice of Hazardous Materials\nCargo Tocks\nResearch and Special Programs Administration\nU.S. Department of Transportation\n05-0200\n4007\" Street SW.,\nWashington, DC 20590-001\nAttn:\nDHM-10\nSec. 178.337-10 Accident damage protection.\n(a) All valves, fittings, pressure relief devices, amd other accessories to the tank proper shall be protected in\naccordance with paragraph (b) of this section against such damage as could be caused by collision with other\nthe event of overturn of the vehicle onto a hard surface, their opening will not be prevented and their discharge\nvehicles or objects, jack-knifing and overturming. In addition, pressure relief valves shall be so protected that ir\nwill not be restricted.\n(b)\nThe protective devices or housing must be designed to withstand static loading in any direction equal to twice the\non the ultimate strength of the material to be used, without damage to the fittings protected, and must be made of\nweight of the tank and attachments when filled with the lading, using a safety factor of not less than four, based\nmetal at least \\3/16\\-inch thick.\nregulations that exempt the \"damage protection\" device if shear sections are provided.\nParagraph. (a) requires accident damage protection whether a shear section is installed or not since there is nothing in the\nQuestion 1:\nIf there is a shear section in the valves on MC-331 tank, is accident damage protection required per\n178.337-10(b)? (Yes or No)\nQuestion 2:\nnot have to comply with 178.337-10(ib)? (Yes or No)\nIf shear sections are provided for the valving and piping then accident damage can be installed, but does\nQuestion 3:\nIf shear sections are not provided for the valving and piping then accident damage protection must be\nprovided per 178.337-10(b)? (Yes or No)\nQuestion 4:\n178.337-10(b) is most likely not feasible and most likely resuits in a very stiff structure that just transfers\nmake it similar to the requirements of DOT-406, DOT-407, and DOT-412 Cargo Tanks?\nthe peak stresses into the vessel wall cor vessel pads. Is this section of the regulation being evaluated to\nSincerely,\nEd MansellI","truncated":false,"body_characters":4493}