# Airgas SAFECOR — Hazardous Materials Safety Interpretation

- **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:** Not available
- **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>>>

U.S. Department of Transportation Pipeline and Hazardous Materials
Safety Administration
MAY 1 7 2011
1200 New Jersey Ave, SE
Washington, D.C. 20590
Mr. John Anderson
Airgas SAFECOR
P.O. Box 20067
Cheyenne, WY 82003
Ref. No.: 11-0067
Dear Mr. Anderson:
This responds to your March 22, 2011 letter requesting clarification of the Hazardous Materials
Regulations (HMR; 49 CFR Parts 171-180) applicable to the general requirements for specification
MC 331 cargo tanks.
In your letter, you state that your company, Airgas SAFECOR (Airgas), carries permitted hazardous
materials within specification MC 331 cargo tank motor vehicles. You state that some of your MC
331 cargo tanks are painted white with a light teal stripe across the horizontal axis of the tank.
Additionally, you state thatXt0ur other MC 331 cargo tanks are "wrapped" in a 3M Controltac™
Graphic Film with Comply v3 Adhesive. The wrap is an ultraviolet (UV) reflective material that is
designed to breathe and resist fading. You provide data of the temperature tests on the striped cargo
tanks and product description data for the wrap. Specifically, you ask whether the light teal stripe
and the wrap are permitted under § 178.337 ofthe HMR.
As specified in § 178.337-1(d), every uninsulated cargo tank permanently attached to a cargo tank
motor vehicle shall, unless covered with a jacket made of aluminum, stainless steel, or other bright
non-tarnishing metal, be painted a white, aluminum or similar reflecting color on the upper two-thirds
of area ofthe cargo tank.
It is the opinion of this Office that both the light teal "striped" and the "wrapped" Airgas cargo tanks
as shown in the photographs and data you supplied do not conflict with § 178.337-1(d); therefore,
you appear to be in compliance with this section.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
-
r-74/Y1./X-~~
......
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

<<<PAGE 2>>>

Ni~ke15
:=s 178. 337"'/(eJ)
Drakeford, Carolyn (PHMSA) Car§o Tankb
From: Billings, Delmer (PHMSA)
Sent: Tuesday, March 22, 2011 11 :31 AM
To: Drakeford, Carolyn (PHMSA)
Cc: Betts, Charles (PHMSA)
Subject: FW: Reflective Design - MC-331 Cargo Tank
Attachments: Cargo tank ASP wrap.JPG; Ammonia cargo tank side view. pdf; fax002216383.pdf
From: John Anderson (SAFECOR) [mailto:John.Anderson.SAFECOR@Airgas.com]
Sent: Wednesday, March 16, 2011 11:30 PM
To: Billings, Delmer (PHMSA); Forbes, Tom
Subject: Reflective Design - MC-331 Cargo Tank
Good evening.
Mr. Billings - per our conversation today we would like your guidance regarding 49 CFR 178.337-1 (d).
Recently an Airgas MC-331 cargo tank in ammonia, anhydrous service was cited in Ohio during a road side inspection
(please see the third attachment) for having a "wrap" on the upper two thirds of the cargo tank (please see the first
attachment). The section of 49 cited is not the correct section but the officer asked us to contact Tom Forbes with the
Ohio PUC for further clarification
We contacted Tom Forbes with the Ohio PUC and he has been very helpful allowing us to contact you to determine if the
"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
material. The wrap is designed to breath. The reflective material is designed so the "wrap" does not fade. The following
is Tom's contact information if you would like to speak directly with him.
Tom Forbe<~
Public Utilities CommissiOll ofOhio
Transportation Department
Compliance Division
180 E(L~t Broad Street, 4tll Floor
Columbus, Ohio 43215-3793
(614) 644-0296 PllOne
(614) 466-2753 Fax
We would also like your guidance on the cargo tank in the second attachment. Airgas purchased the assets of LaRoche
Industries in June of 2005 which included approximately 100 MC-331 cargo tanks in ammonia, anhydrous service.
LaRoche Industries painted the stripe on these cargo tanks a dark blue (beginning in 1992). After the Airgas acquisition
we painted the stripe a light teal color (Airgas color). Today we operate approximately 95 MC-331 cargo tanks with the
teal stripe and about 5 MC-331 cargo tanks with the "wrap". We have never had an issue with the stripe (since 1992) or
the wrap (which is about 2 years old) but since this issue has been raised by the State of Ohio we would like your
guidance.
The cargo tanks are dedicated to ammonia, anhydrous service and we have not experienced any problems with pressure
due to the stripe or wrap. A lot of the LaRoche management team joined Airgas and in talking with them they have never
received a citation over the stripe or wrap until this issue was raised. The striped and wrapped cargo tanks have received
an annual visual inspection by numerous cargo tank testing facilities over the years and they have never failed their
annual visual inspection due to the stripe or wrap.
Thank you for your help resolving this issue.
John Anderson
Airgas SAFECOR
P.O. Box 20067
Cheyenne. WY 82003
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