{"operation":"document","citation":"13-0037","title":"Public Utilities Commission of Ohio Transportation Department — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-05-06","effective_on":null,"summary":"13-0037 response to Public Utilities Commission of Ohio Transportation Department concerning 178.704.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0037.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0037.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0037","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130037.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nMAY 0 6 2013\nMr. Tom Forbes\nPublic Utilities Commission of Ohio\nTransportation Department\n180 E. Broad St. 4th Floor\nColumbus, OH 43215\nRef. No .. : 13-0037\nDear Mr. Forbes:\nThis responds to your February 5, 2013 letter requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) applicable to intermediate bulk container (IBC)\ndischarge valves. As an attachment to the letter, you included multiple pictures of an IBC with\nvarious views of the bottom discharge valves. You ask whether the IBC in the pictures meets the\ngeneral requirements of§ 178.704(e); specifically, that the open or closed position of each valve\nis readily apparent.\nThe answer is yes. As required in § 178. 704( e), bottom discharge valves must be secured in the\nclosed position and the discharge system suitably protected from damage. Valves having lever\nclosures must be secured against accidental opening. The open or closed position of each valve\nmust be readily apparent. For each IBC containing a liquid, a secondary means of sealing the\ndischarge aperture must also be provided, e.g., by a blank flange or equivalent device.\nIn the pictures you provided, the position of the discharge valve is readily apparent and conforms\nto standard operating designs for quarter turn valves (e.g., ball valve, butterfly valve, plug valve,\netc.). When the handle is perpendicular to the pipe axis, the indication is that the valve is closed.\nWhen the handle is in-line with the pipe axis, the indication is that the valve is open. Therefore,\nit is the opinion of this Office that the IBC discharge valve included in the pictures complies with\nthe requirement that the open or closed position of each valve must be readily apparent pursuant\nto§ 178.704(e).\nI hope this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom:\nINFOCNTR (PHMSA)\nSent:\nTuesday, February 05, 2013 3:49 PM\nTo:\nDrakeford, Carolyn (PHMSA)\nSubject: FW: PHMSA Interpretation Request\nAttachments: 3213302191PIP 004.jpg; 3213302191PIP 006.jpg; The ball valve.pdf\nHi Carolyn,\nWe received the following request for a formal letter of interpretation.\nThanks,\nVictoria\nFrom: Forbes, Tom [mailto:Tom.Forbes@puc.state.oh.us]\nSent: Tuesday, February 05, 2013 1:31 PM\nTo: PHMSA HM InfoCenter\nCc: mdaniel@landstar.com; Forbes, Tom\nSubject: PHMSA Interpretation Request\nDear Sir or Madame:\nI am requesting a written interpretation/clarification on the IBC discharge valve requirements under the Hazardous\nMaterials\nRegulations (HMR 49 CFR Parts 171-180).\nSpecifically, 178.704(e) states the open or closed position of each valve must be readily apparent.\nThe IBCs in this case have no marking or other indication of the open/closed position (178.704(e) does not require\nsuch marking). It is the carriers/shippers position that the handle that is attached to the ball is in-line with the axis\nof the pipe when the valve is open; conversely, if it is at right angles to the pipe axis, this indicates that the valve is\nclosed. They believe the position of the valve is readily apparent.\nAn inspection was conducted and a violation listed for 178.704(e) IBC bottom discharge valve; open/closed position\nnot readily apparent.\nPhotos of the IBCs and bottom valve are attached.\nCould you please provide some guidance on whether the valve position on the IBCs in these photos is readily\napparent.\nThank you for your assistance on this matter.\nTom Forbes\nPublic Utilities Commission of Ohio\nTransportation Department\n180 E Broad St 4tH Floor\nColumbus, Ohio 43215\nHazardous Materials Specialist\n(614) 644-0296\nPUCO.ohio.gov\n1\n\n<<<PAGE 3>>>\n\nThis message and any response to it may constitute a public record and thus may be publicly\navailable to anyone who requests it.\n2\n\n<<<PAGE 4>>>\n\nThe ball valve, along with the butterfly valve and plug valve, are part of the family of quarter\ntum valves. (Rotary movement) Rotary movement valves tend to have a simple operating\nmechanism and are therefore easy to automate and maintain. The body of ball valves may be\nmade of metal or plastic, in our case these valves are manufactured of plastic.\nConventionally, the handle that is attached to the ball is in-line with the axis of the pipe when\nthe valve is open; conversely, if it is at right angles to the pipe axis, this indicates that the\nvalve is closed.\nWhen the valve is closed, the hole and valve lever are perpendicular to the ends of the valve,\nand flow is blocked.\nThese valves are also equipped with a safety screw that must be removed before the valve can be\nopened.\nHandle perpendicular- Valve closed\nWhen the valve is open the handle I lever is in-line with the axis of the pipe.\n,fnd view of the ball within the nlve at different\nstages of rot<~tion\nValv-e\nfJI\\' oper\nv~:ve\nIt, DOe:·!\nBall valve (shown in its open position)\n\n<<<PAGE 5>>>\n\n\n\n<<<PAGE 6>>>\n\nULTIPR\n17600","truncated":false,"body_characters":5089}