{"operation":"document","citation":"18-0086","title":"KASI Infrared Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-09-20","effective_on":null,"summary":"18-0086 response to KASI Infrared Corporation.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0086.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0086.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0086","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/69251/180086.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nSEP 2 0 2018\nTom Allen\nKASI Infrared Corporation\n931 John Stark Highway\nNewport, NH 03773\nReference No. 18-0086\nDear Mr. Allen:\nThis letter is in response to your June 6, 2018, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements for\npermanently mounted propane tanks for which the sole purpose is powering equipment that is\nmounted on the truck. Specifically, you ask whether the transport vehicle in the photographs\nprovided is subject the placarding requirements of Part 172, Subpart F of the HMR.\nThe answer is no. Provided the permanently mounted propane tanks meet the requirements of\n49 CFR 393.65 and 393.67 of the Federal Motor Carrier Safety Regulations (FMCSR) for fuel\nsystems and are used only for supplying fuel for the operation of the motor vehicle or its\nauxiliary equipment, the mounted propane tanks are not subject to the HMR with respect to their\nuse on the vehicle.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\n~~\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nJanuary, lkeya CTR (PHMSA)\nFrom:\nSent:\nTo:\nCc:\nDerKinderen, Dirk (PHMSA)\nThursday, June 07, 2018 4:13 PM\nJanuary, Ikeya CTR (PHMSA)\nGeller, Shelby (PHMSA)\nSubject: FW: Request for Clarification\nlkeya,\nPlease enter in Filemaker as an interp request and please reach out to Mr. Allen for the photos that he refers to in the\ntext of his email. I don't see the attached photos.\nSincerely.\nD Wlv Dev KC,n,de,ve-¥v\nFrom: Raynor, T'Mia (PHMSA)\nSent: Thursday, June 07, 2018 4:10 PM\nTo: DerKinderen, Dirk (PHMSA) <Dirk.DerKinderen@dot.gov>\nSubject: FW: Request for Clarification\nHello,\nThis was received in the webmaster inbox.\nThanks,\nT'Mia Raynor\nWebmaster\nPHMSA Office of the CIO (PHF-30)\nDesk: (202) 366-9818 I Mobile: (202) 580-9447\nFrom: Tom Allen <tom@kasiinfrared.com>\nSent: Thursday, June 7, 2018 3:34:16 PM\nTo: PHMSA Webmaster\nSubject: Request for Clarification\nJUNE 6, 2018\nTO: Office of Hazmat Standards\nDirk Der Kinderen\nEast Building\n1200 N.J. Avenue SE\nWashington, DC 20590\nFROM:\nTom Allen\n1\n\n<<<PAGE 3>>>\n\nSUBJECT: General Manager\nKASI Infrared C orporation\n931 John Stark Highway .\nNewport, NH 03773\nRequest for determination of placarding\nWe have periodically been asked by customers if placarding and hazmat certification was required on this equipment. In\neach instance we called you folks and were told that as long as the fuel tanks meet FMCSA 49 CFR 393.65 and.67\nregulation as the fit for this equipment and that the tanks were permanently mounted and for the sole purpose of\npowering the truck mounted equipment that no placarding was required. The key points we were referred to were that\nthis is a permanently mounted system with permanently affixed tanks ;md the propane vapor was utilized solely for the\noperation of the system. We have two tank configurations depending on the amount of fuel necessary for operation of\nthe systems. The smaller systems carry five 100 LB DOT Multi-Valve LPG Vapor Draw Tanks and the larger systems carry\ntwo 420 LB DOT Multi-Valve LPG Vapor Draw Tanks. We would like to have an interpretation to make certain we are\nCorrect regarding placarding.\nI have attached photos of the systems referred to above\nThank you\n2\n\n<<<PAGE 4>>>\n\n\n\n<<<PAGE 5>>>","truncated":false,"body_characters":3501}