{"operation":"document","citation":"11-0067","title":"Airgas SAFECOR — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-05-17","effective_on":null,"summary":"11-0067 response to Airgas SAFECOR concerning 178.337.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0067.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0067.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0067","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110067.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\nMAY 1 7 2011\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nMr. John Anderson\nAirgas SAFECOR\nP.O. Box 20067\nCheyenne, WY 82003\nRef. No.: 11-0067\nDear Mr. Anderson:\nThis responds to your March 22, 2011 letter requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) applicable to the general requirements for specification\nMC 331 cargo tanks.\nIn your letter, you state that your company, Airgas SAFECOR (Airgas), carries permitted hazardous\nmaterials within specification MC 331 cargo tank motor vehicles. You state that some of your MC\n331 cargo tanks are painted white with a light teal stripe across the horizontal axis of the tank.\nAdditionally, you state thatXt0ur other MC 331 cargo tanks are \"wrapped\" in a 3M Controltac™\nGraphic Film with Comply v3 Adhesive. The wrap is an ultraviolet (UV) reflective material that is\ndesigned to breathe and resist fading. You provide data of the temperature tests on the striped cargo\ntanks and product description data for the wrap. Specifically, you ask whether the light teal stripe\nand the wrap are permitted under § 178.337 ofthe HMR.\nAs specified in § 178.337-1(d), every uninsulated cargo tank permanently attached to a cargo tank\nmotor vehicle shall, unless covered with a jacket made of aluminum, stainless steel, or other bright\nnon-tarnishing metal, be painted a white, aluminum or similar reflecting color on the upper two-thirds\nof area ofthe cargo tank.\nIt is the opinion of this Office that both the light teal \"striped\" and the \"wrapped\" Airgas cargo tanks\nas shown in the photographs and data you supplied do not conflict with § 178.337-1(d); therefore,\nyou appear to be in compliance with this section.\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\n-\nr-74/Y1./X-~~\n......\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nNi~ke15\n:=s 178. 337\"'/(eJ)\nDrakeford, Carolyn (PHMSA) Car§o Tankb\nFrom: Billings, Delmer (PHMSA)\nSent: Tuesday, March 22, 2011 11 :31 AM\nTo: Drakeford, Carolyn (PHMSA)\nCc: Betts, Charles (PHMSA)\nSubject: FW: Reflective Design - MC-331 Cargo Tank\nAttachments: Cargo tank ASP wrap.JPG; Ammonia cargo tank side view. pdf; fax002216383.pdf\nFrom: John Anderson (SAFECOR) [mailto:John.Anderson.SAFECOR@Airgas.com]\nSent: Wednesday, March 16, 2011 11:30 PM\nTo: Billings, Delmer (PHMSA); Forbes, Tom\nSubject: Reflective Design - MC-331 Cargo Tank\nGood evening.\nMr. Billings - per our conversation today we would like your guidance regarding 49 CFR 178.337-1 (d).\nRecently an Airgas MC-331 cargo tank in ammonia, anhydrous service was cited in Ohio during a road side inspection\n(please see the third attachment) for having a \"wrap\" on the upper two thirds of the cargo tank (please see the first\nattachment). The section of 49 cited is not the correct section but the officer asked us to contact Tom Forbes with the\nOhio PUC for further clarification\nWe contacted Tom Forbes with the Ohio PUC and he has been very helpful allowing us to contact you to determine if the\n\"wrap\" as shown in the first attachment complies with 178.337-1 (d). The wrap is made by 3M and it is a UV reflective\nmaterial. The wrap is designed to breath. The reflective material is designed so the \"wrap\" does not fade. The following\nis Tom's contact information if you would like to speak directly with him.\nTom Forbe<~\nPublic Utilities CommissiOll ofOhio\nTransportation Department\nCompliance Division\n180 E(L~t Broad Street, 4tll Floor\nColumbus, Ohio 43215-3793\n(614) 644-0296 PllOne\n(614) 466-2753 Fax\nWe would also like your guidance on the cargo tank in the second attachment. Airgas purchased the assets of LaRoche\nIndustries in June of 2005 which included approximately 100 MC-331 cargo tanks in ammonia, anhydrous service.\nLaRoche Industries painted the stripe on these cargo tanks a dark blue (beginning in 1992). After the Airgas acquisition\nwe painted the stripe a light teal color (Airgas color). Today we operate approximately 95 MC-331 cargo tanks with the\nteal stripe and about 5 MC-331 cargo tanks with the \"wrap\". We have never had an issue with the stripe (since 1992) or\nthe wrap (which is about 2 years old) but since this issue has been raised by the State of Ohio we would like your\nguidance.\nThe cargo tanks are dedicated to ammonia, anhydrous service and we have not experienced any problems with pressure\ndue to the stripe or wrap. A lot of the LaRoche management team joined Airgas and in talking with them they have never\nreceived a citation over the stripe or wrap until this issue was raised. The striped and wrapped cargo tanks have received\nan annual visual inspection by numerous cargo tank testing facilities over the years and they have never failed their\nannual visual inspection due to the stripe or wrap.\nThank you for your help resolving this issue.\nJohn Anderson\nAirgas SAFECOR\nP.O. Box 20067\nCheyenne. WY 82003\n1","truncated":false,"body_characters":5058}