Guidanceguidance
17-0020
Keehn Service Corporation — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research17-0020
Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590 Materials Safety Pipeline and Hazardous Administration APR 0 2 2018 Stephen Kovacic Keehn Service Corporation 99 N. 11th Avenue Coatesville, PA 19320 Reference No. 17-0020 Dear Mr. Kovacic: This letter is in response to your February 13, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking requirements for a Department of Transportation (DOT) Specification MC 331 cargo tank. Specifically, you ask if § 178.337-9(c) allows the inlet/outlet marking to be placed on guarding, supports, or interlock paddles on an MC 331 cargo tank as it relates to guidance offered in a previously-issued letter of interpretation. You also provide photographs illustrating the placement of your markings on an MC 331 cargo tank motor vehicle. The answer is yes. In accordance with § 178.337-9(c), each cargo tank inlet and outlet, with the exception of gauging devices, thermometer wells, and pressure relief devices, must be marked "liquid" or "vapor" to designate whether it communicates with liquid or vapor when the cargo tank is filled to the maximum permitted filling density. Provided the marking is readily visible, legible, durable to withstand transport conditions, and clearly associated with the corresponding inlet/outlet, the marking would satisfy the requirements of the HMR. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Shane Kelley Director Standards and Rulemaking Division#
Page 2Andrews 8/78.337-9c Dodd, Alice (PHMSA) Packagung specs From: 170020 Sent: INFOCNTR (PHMSA) To: Tuesday, February 14, 2017 5:09 PM Subject: Hazmat Interps Attachments: FW: Clarification of Ref. No. 16-0001 20170202_074334 jpg; 20170202_074702.jpg Hi Shante/Alice, Please submit this as a letter of interpretation. Please let me know if you have any questions. Thanks, Jordan From: steve [mailto: steve@keehnservice.com] Sent: Tuesday, February 14, 2017 1:33 PM To: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov> Subject: Fw: Clarification of Ref. No. 16-0001 Please submit this for formal letter of interpretation. Regards, Stephen Kovacic Keehn Service Corp 99 N 11th Ave Coatesville, PA 19320 610-384-6851 steve@keehnservice.com -----Original Message----- From: steve <steve@keehnservice.com> To: phmsa.hm-infocenter@dot.gov Date: 02/13/17 08:33 Subject: Clarification of Ref. No. 16-0001 I am requesting a clarification of US DOT Pipeline and Hazardous Materials Safety Administration interpretation No. 16- 0001. in close proximity to its respective make/break connection point, rather then on the cargo tank wall." The issued interpretation letter states that " The required markings must be on the inlet and outlet equipment itself and I am requesting that a clarification to the phrase "marking be on the inlet and outlet equipment itself" does not specifically refer to the piping and inlet and outlet valve(s) but the word "equipment" is used in a broader context allowing the markings to be placed on guarding, supports or interlock paddles "in close proximity to its respective make/break connection points". Most commonly placed as shown in the attached photos. Thank you for your attention in this matter.#
Page 3Regards, Stephen Kovacic Keehn Service Corp 99 N 11th Ave 610-384-6851 Coatesville, PA 19320 steve@keehnservice.com 2#
Page 4LIQUID LIOUT VAPOR#
Page 5OF MARtING STENCIL#
Page 6CLIQUID#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.