{"operation":"document","citation":"24-0044","title":"The National Board of Boiler and Pressure Vessel Inspectors — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-03-04","effective_on":null,"summary":"24-0044 response to The National Board of Boiler and Pressure Vessel Inspectors concerning 180.407, 180.413.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0044.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0044.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0044","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-03/24-0044.pdf","body":"<<<PAGE 1>>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nMarch 4, 2025\nLuis Ponce\nManager of Technical Services\nThe National Board of Boiler and Pressure Vessel Inspectors\n1055 Crupper Avenue\nColumbus, OH 43229-1183\nReference No. 24-0044\nDear Mr. Ponce:\nThis letter is in response to your May 29, 2024 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to Department of\nTransportation (DOT) specification cargo tank repair requirements. Specifically, you state that\nthe National Board of Boiler and Pressure Vessel Inspectors (NBBI) publishes its flagship\npublication—i.e., the National Board Inspection Code (NBIC)—every two years. You further\nstate that the next edition—for 2025—will see a complete rewrite of Supplement 6 “Repair,\nAlteration, and Modification of DOT Transport Tanks,\n” and that there will be changes to the\npressure testing of repairs and alterations to line up with DOT requirements. You ask for\nclarification on whether “applicable manufacturing specification” means a DOT specification or\nanother code of construction.\nWe have paraphrased and answered your questions as follows:\nQ1. Does the phrase “applicable manufacturing specification” in § 180.413(b) refer to the\noriginal code of construction, such as the American Society of Mechanical Engineers\n(ASME) Code?\nA1. No. As specified in § 180.413(b), the suitability of each repair affecting the structural\nintegrity or lading retention capability of the cargo tank must be determined by the testing\nrequired either in the applicable manufacturing specification or in § 180.407(g)(1)(iv).\nThe phrase “applicable manufacturing specification” means the authorized DOT\nspecification.\n\n<<<PAGE 2>>>\n\nQ2. If the answer to Q1 is yes, can the requirements of either the original code of construction\nor Part 180 be used for repairs by an NBBI “R” stamp certificate holder?\nA2. See answer A1.\nWe hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division","truncated":false,"body_characters":2203}