{"operation":"document","citation":"17-0058","title":"Hazmat Environmental Group — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-11-14","effective_on":null,"summary":"17-0058 response to Hazmat Environmental Group concerning 180.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0058.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0058.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0058","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/56201/170058.pdf","body":"<<<PAGE 1>>>\n\nVince Phillips\nMaintenance Supervisor\nHazmat Environmental Group\n60 Commerce Drive\nBuffalo, NY 14218-1040\nReference No. 17-0058\nDear Mr. Phillips:\nThis letter is in response to your June 1, 2017, letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to inspection requirements for\nthe areas on a cargo tank covered by the upper coupler (fifth wheel). You describe a lined cargo\ntank transporting lading that is corrosive to the tank but due to the lining does not come in\ndirect contact with the tank itself. You ask whether the areas covered by the upper coupler (fifth\nwheel) must be tested every two years in accordance with § 180.407(d)(2)(ix), even though the\ntank is lined\nThe answer is yes. Section 180.407(d)(2)(ix) requires that when transporting lading corrosive to\nthe tank, areas on a cargo tank covered by the upper coupler (fifth wheel) must be inspected once\nevery two years for corroded and abraded areas, dents, distortions, defects in welds, and any\nother condition that might render the tank unsafe for transportation service. The lading you\ndescribe is corrosive. Therefore, even though the lading does not physically come in contact\nwith the tank, the HMR require that the inspection be completed every two years.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\n180.407(d)(2)(ix) For cargo tanks transporting lading corrosive to the tank, areas\ncovered by the upper coupler (fifth wheel) assembly must be inspected at least\nonce in each two year period for corroded and abraded areas, dents, distortions,\ndefects in welds, and any other condition that might render the tank unsafe for\ntransportation service. The upper coupler (fifth wheel) assembly must be\nremoved from the cargo tank for this inspection.\nThe part of \"For cargo tanks transporting lading corrosive to the tank\" is\nwhere my question comes in regarding a lined cargo tank, although the lading in\nthe tank is corrosive to the tank it does not ever touch the tank as it is lined.\nCould in this instance the coupler removal then go back to following under\n180.407(g)(1)(iii) for 5 year pressure testing criteria. We are asking this under the\npremise in this case where it is an uninsulated, unjacketed, and the upper coupler\n(fifth wheel) does not interfere with completing a full external visual inspection of\nthe cargo tank, appurtenances, and structural attachments on this cargo tank.\nThank you. Sincerely,\nVince Phillips\nMaintenance Supervisor\nHazmat Environmental Group\n60 Commerce Drive\nBuffalo NY 14218-1040\nvphillips@hazmatinc.com\n0-716-748-8267 / C- 716-572-6351 / fax 716-748-8360","truncated":false,"body_characters":2747}