{"operation":"document","citation":"15-0221","title":"Mr. Edwin Jackson — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-04-26","effective_on":null,"summary":"15-0221 concerning 180.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0221.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0221.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0221","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2016/150221.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMaterials Safet\nipeline and Hazardou\nAdministration\nAPR 2 6 2016\nEdwin Jackson\nPetroleum Fleet Specialists\nPO Box 1024\nMarshal, VA 20116\nRef. No. 15-0221\nDear Mr. Jackson:\nThis responds to your November 6, 2015 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the visual inspection of\ncargo tanks as it relates to vinyl wrapping. Specifically, you ask whether a vinyl decal is\nconsidered a lining or coating as provided in § 180.407(d)(1).\nA vinyl decal is not considered a lining or coating, but may restrict a proper external visual\ninspection from being performed. Section 180.407(c) requires all specification cargo tanks to\nhave an external visual inspection at least once each year. As provided in § 180.407(d)(1), if\nexternal visual inspection is precluded because any part of the cargo tank wall is externally\nlined, coated, or designed to prevent an external visual inspection, those areas of the cargo\ntank must be internally inspected. Thus, if the outside of a cargo tank is covered with a vinyl\ndecal that prevents the inspector from performing an external visual inspection (e.g.,\ninspecting welds for cracks, shell for pitting, etc.), the cargo tank requires an internal visual\ninspection for the affected areas, in conjunction with an external visual inspection. However,\nif the decal still allows for an external visual inspection, an internal visual inspection would\nnot be required.\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nliccarone\n§ 180.407(8)(1)\nl'argo Tanks\nDodd, Alice (PHMSA)\n15-0221\nFrom:\nSent:\nGeller, Shelby CTR (PHMSA)\nMonday, November 09, 2015 1:25 PM\nTo:\nSubject:\nHazmat Interps\nFW: Formal interpretation of Ref.No.: 14-0110\nDear Shante and Alice,\naddress is:\nBelow is a request for a formal letter of interpretation. Mr. Jackson spoke with Jordan Rivera in the HMIC. His mailing\nPetroleum Fleet Specialist\nPO BOX 1024\nMarshal, VA 20116\nThanks,\nShelby\nFrom: Edwin Jackson [mailto:edwin@petrofleet.com]\nTo: PHMSA HM InfoCenter\nSent: Friday, November 06, 2015 3:12 PM\nSubject: Formal interpretation of Ref.No.: 14-0110\nI would like to have a recorded clarification of a response with Ref. No.: 14-0110.\nThe question specifically was about wrapped tanks being covered by vinyl stickers not allowing the shell to\nbe visibly inspected from the outside requiring an internal inspection.\nThe reply used verbiage from 180.407(d)(1) which says if ANY piece of the shell is lined or coated so that you\ncan not see the shell it needs to be internally inspected\nSo I guess the main question now, is a vinyl decal considered a lining or coating? If so pretty much 90% of all\n306 & 406 tanks would need to be internally inspected due to having some type of decal on it. If you want to get\ntechnical that would mean a stick on placard would require an internal inspection or removing the placard to\nlook at the shell under it.\nThis was brought to my attention by one of your Hazmat Material Specialist and he asked me to get a\nclarification.\nFor what it is worth I do not agree with this. My experience removing decals, I would say if anything it is a\nprotective coating for at least corrosion. You can see any gouge or dent under the vinyl decal. And for the most\npart any crack you find in a weld is going to be leaking and that will show up just as much if not worse from a\nmelting decal. Further more an internal inspection is not going to show a gouge on the outside of the shell\nonly a dent..\nA structural crack say at an outrigger pad would be covered by a wrap but an internal would not find it either.\nAnother question would be if you are required to do an internal to inspect the shell that is covered by the decal\nare you required to look at the baffles or any other internal components that would only be inspected during a 5\nyear?\n1\n\n<<<PAGE 3>>>\n\nIf it is decided that a vinyl decal is considered a lining or coating this changes everything and it needs to\nbe known.\nThank you for your help in this matter\nSincerely,\n--\n****** PFS*******\n@)(@)\nEdwin Jackson\nPetroleum Fleet Specialists\n540.222.1506\n2","truncated":false,"body_characters":4356}