DOT Training Solutions — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 February 2, 2023 Arturo Prado DOT Training Solutions 701 Briar Court Brownsville, TX 78521 Reference No. 22-0121 Dear Mr. Prado: This letter is in response to your November 4, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the configuration of bulk trailer valves. You ask whether a DOT 407 cargo tank motor vehicle (CTMV), manufactured as a “wheels back” vehicle, as defined in 49 CFR § 393.5, fitted with a rear loading valve located behind the fifth axle, and in full tow configuration is required to have an internal self-closing stop valve with a sacrificial device. According to § 178.345-8 and when solely considering accident damage protection, an internal self-closing stop-valve with a sacrificial device is required only when seeking relief from § 178.345-8(b)(1). When a sacrificial device is required, it is subject to the strength and location requirements found in § 178.345-8(b)(2). However, based on the photographs and information you provided, we are unable to make the determination whether the configuration presented meets the requirements of § 178.345-8(b)(1) or § 178.345-8(b)(2). Additionally, the CTMV is still subject to the remaining requirements found in § 178.345-8, as well as any other applicable requirements (i.e., tank outlet requirements found in § 178.345-11). These other requirements must also be taken into consideration when making a final determination for valve requirements. Please note, this Office does not make the determination whether specific individual configurations meet the applicable requirements of the HMR. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Baker From: INFOCNTR (PHMSA) To: Hazmat Interps Subject: FW: Bulk trailer valve configuration 178.345-8 Date: Friday, November 4, 2022 3:56:07 PM Attachments: image001.png 178.345-8 vs wheels back.pdf 22-0121 Hello Hazmat Interps, See below and attached request for interpretation. Thanks, Jonathon, CTR From: Arturo Prado <arturoprado@dottrainingsolutions.com> Sent: Friday, November 4, 2022 2:22 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: FW: Bulk trailer valve configuration 178.345-8 CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. As requested here is my physical mailing address: 701 Briar Court, Brownsville, Texas 78521 Arturo Prado Safety Consultant Mobile: (913) 350-0371 or (956) 455-6986/Toll Free: (866) 296-7394 Email: arturoprado@dottrainingsolutions.com Website: https://dottrainingsolutions.com From: Arturo Prado Sent: Wednesday, October 26, 2022 2:14 PM To: PHMSA.Pipelinesafety@dot.gov Cc: James Dean <jdean@altomtransport.com> Subject: Bulk trailer valve configuration 178.345-8#

Page 3393.86 Rear impact guards and rear end protection. (a)(1) The requirements of paragraph (a) of this section do not apply to pole trailers (as defined in §390.5 of this chapter); pulpwood trailers, low chassis vehicles, special purpose vehicles, wheels back vehicles (as defined in §393.5); and trailers towed in driveaway-towaway operations (as defined in § 390.5). 393.5 Definitions Wheels back vehicle. (1) A trailer or semitrailer manufactured on or after January 26, 1998, whose rearmost axle is permanently fixed and is located such that the rearmost surface of the tires (of the size recommended by the vehicle manufacturer for the rear axle) is not more than 305 mm (12 inches) forward of the transverse vertical plane tangent to the rear extremity of the vehicle. 178.345-8 Accident damage protection. (b)(1) Any bottom damage protection device must be able to withstand a force of 155,000 pounds (based on the ultimate strength of the material) from the front, side, or rear, uniformly distributed over each surface of the device, over an area not to exceed 6 square feet, and a width not to exceed 6 feet. Suspension components and structural mounting members may be used to provide all, or part, of this protection. The device must extend no less than 6 inches beyond any component that may contain lading in transit. 178.345-8 Accident damage protection#

Page 4Betts External Chemical Hydraulic Valve is classified as an external self-closing stop valve and is widely used on DOT407 and 412 cargo tanks. This is a robust and proven valve that satisfies the many requirements of the chemical transportation industry. The 316-stainless body and replaceable Teflon seal make this valve a versatile and reliable workhorse for any fleet. This valve does NOT include a sacrificial shear section; therefore, the cargo tank must have adequate accident damage protection to shield the valve as specified in 49CFR §178.345-8.#

Page 5178.345-8 Accident damage protection. (b)(1) Any bottom damage protection device must be able to withstand a force of 155,000 pounds (based on the ultimate strength of the material) from the front, side, or rear, uniformly distributed over each surface of the device, over an area not to exceed 6 square feet, and a width not to exceed 6 feet. Suspension components and structural mounting members may be used to provide all, or part, of this protection. The device must extend no less than 6 inches beyond any component that may contain lading in transit.#

Page 6393.5 Definitions Wheels back vehicle. (1) A trailer or semitrailer manufactured on or after January 26, 1998, whose rearmost axle is permanently fixed and is located such that the rearmost surface of the tires (of the size recommended by the vehicle manufacturer for the rear axle) is not more than 305 mm (12 inches) forward of the transverse vertical plane tangent to the rear extremity of the vehicle. 178.345-8 Accident damage protection. (b)(1) Any bottom damage protection device must be able to withstand a force of 155,000 pounds (based on the ultimate strength of the material) from the front, side, or rear, uniformly distributed over each surface of the device, over an area not to exceed 6 square feet, and a width not to exceed 6 feet. Suspension components and structural mounting members may be used to provide all, or part, of this protection. The device must extend no less than 6 inches beyond any component that may contain lading in transit.#

Page 7Question does a DOT 407 cargo tank that was manufacture with wheels back configuration (393.5) and fitted with rear loading valve required to have an internal valve with a sacrificial device? If the valve is located aft of axle 5 when in full tow configuration, and section 178.345-8 states that the suspension components and structural mounting members may be used to provide all, or part, of this protection. Does this configuration located close to the aft axle relief carrier or manufacture from installing a internal valve with a sacrificial device. Arturo Prado Safety Consultant Mobile: (913) 350-0371|Toll Free: (866) 296-7394 Email: arturoprado@dottrainingsolutions.com Website: https://dottrainingsolutions.com From: James Dean <jdean@altomtransport.com> Sent: Wednesday, October 19, 2022 9:50 AM To: Arturo Prado <arturoprado@dottrainingsolutions.com> Subject: Bulk trailer valve configuration Get Outlook for iOS CONFIDENTIALITY NOTICE: This email message is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. If you received this electronic transmission in error, please be aware that any unauthorized review; copying, use, disclosure or distribution of this information is prohibited. If you are not the intended recipient, please contact the sender by reply email, then delete the original message, including any attachments, and destroy all copies.#

Page 8HEEL DID YOU CHECE A DANGER A DANGER EMERGENCY SHUTOFF Steam outlet LTOM Transport, Inc.#