{"operation":"document","citation":"17-0042","title":"Trinity Industrials. LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-08-14","effective_on":null,"summary":"17-0042 response to Trinity Industrials. LLC concerning 178.337.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0042.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0042.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0042","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/170042.pdf","body":"<<<PAGE 1>>>\n\nConsultant\nTrinity Industries, LLC\n2525 Stemmons Freeway\nDallas, TX 75207\nReference No. 17-0042\nDear Mr. McRae:\nThis letter is in response to your April 26, 2017, letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to MC 331 cargo tanks.\nSpecifically, you seek clarification of the requirements to provide heat treatment information on\nthe Department of Transportation certificate of compliance when heat treatment is not required\nto be performed on an MC 331 cargo tank constructed of other than quenched and tempered\n(NQT) carbon steel.\nIn general, the certificate of compliance does not need to contain a statement whether or not a\ncargo tank was postweld heat treated. However, it is the opinion of this Office that postweld\nheat treatment can be permissively indicated on the certificate of compliance if the manufacturer\nchooses to disclose this information. According to § 178.337-1(f), postweld heat treatment must\nbe as prescribed in the American Society of Mechanical Engineers (ASME) Code except that\neach cargo tank constructed in accordance with Part UHT of Section VIII of the ASME Code\nmust be postweld heat treated. If an MC 331 cargo tank has been postweld heat treated, this\ninformation must be indicated on the name plate in accordance with the applicable requirements\nof the ASME Code.\nPlease note, there are different requirements for the certificate of compliance for cargo tanks\nused for anhydrous ammonia service (see § 178.337-18(a)(6)).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nthe tte\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\ne-mail: infocntr@dot.gov\nStandards and Rulemaking Division\nPipeline and Hazardous Material safety Administration\nEast Building, 2 Floor\nWashington D.C. 20590-0001\nAttn: PPH-10\nRequest for Interpretation\nReference: CFR 178.337-18 D.O.T. Certification of Compliance\nPlease provide clarification as to information that is to appear on a manufactures Certificate of\nCompliance for MC-331 cargo tanks.\nBackground: MC-331 cargo tank manufactured of carbon steel, NQT material, and are not required to\nbe heat treated by D.O.T. regulation or ASME code.\nWhen heat treatment is required by ASME and DOT regulations the manufactures nameplate is\nstamped with the required marking and so noted on the manufactures U1-A data report.\nQuestion: Is the manufacture required to also list functions that are not required to be performed such\nas heat treatment for the cargo tank described above that is not required to be heat treated?\nPlease contact me if you have any questions. I may be reached via phone at 214.589.8559 or email:\ngreg.mcrae@trin.net\nConsultant\nTrinity Industries, LLC.\n2525 Stemmons Freeway, Dallas, TX 75207--\n-P.O. Box 75356 Dallas, TX 75356-8887","truncated":false,"body_characters":2881}