{"operation":"document","citation":"25-0043","title":"Betts Industries, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-07-02","effective_on":null,"summary":"25-0043 response to Betts Industries, Inc. concerning 173.24, 178.345, 178.346, 178.347, 178.348.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0043.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0043.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0043","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-07/250043.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nJuly 2, 2025\nDavid J. Adams\nDirector of Design Engineering\nBetts Industries, Inc.\n1800 Pennsylvania Ave. West\nWarren, PA 16365\nReference No. 25-0043\nDear Mr. Adams:\nThis letter is in response to your April 10, 2025 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to a cargo tank motor vehicle\n(CTMV). Specifically, you ask about the use of an engineered copolymer as the material of\nconstruction for certain parts of a CTMV.\nWe have paraphrased and answered your questions as follows:\nQ1. Does the requirement for the use of nonmetallic materials outlined in § 178.345-9(h)\napply to the body of a pressure relief device (PRD), such as a normal vent used on a\nDepartment of Transportation (DOT) 406 CTMV?\nA1. No. Section § 178.345-9(h) is applicable for components outboard of the lading retention\nsystem and does not apply to PRDs. PRD requirements are generally outlined in\n§ 178.345-10 for DOT 400 series CTMVs, and further specified in §§ 178.346-3,\n178.347-4, and 178.348-4 for DOT 406, DOT 407, and DOT 412 CTMVs, respectively.\nQ2. Does the HMR prohibit the use of a high-performance engineered copolymer as the\nmaterial of construction for the body of a normal vent on a DOT 406 CTMV?\n\n<<<PAGE 2>>>\n\nA2. No. The HMR do not specify requirements or restrictions pertaining to materials of\nconstruction for PRDs on DOT 406 CTMVs; however, the pressure relief system—\nincluding normal vents—must meet the performance requirements in §§ 178.345 and\n178.346, as well as the general packaging compatibility requirement in § 173.24\nregarding the use of a packaging and its lading.\nI 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\n\n<<<PAGE 3>>>\n\nCasey, C.\n25-0043\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps; Baker, Yul (PHMSA)\nSubject: FW: Request for Interpretation 49CFR§178.345-9\nDate: Thursday, April 10, 2025 10:48:28\nHi Alice,\nPlease see the below interpretation request.\nLet me know if you need anything,\n-Breanna\nFrom: David J. Adams <dadams@bettsind.com>\nSent: Thursday, April 10, 2025 9:23 AM\nTo: PHMSA Website Manager <PHMSAWebsiteManager@dot.gov>\nCc: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: Request for Interpretation 49CFR§178.345-9\nSome people who received this message don't often get email from dadams@bettsind.com. Learn why this is important\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nTo Whom It May Concern,\nI would like to request a regulation interpretation or clarification.\nCurrent regulation reads:\n49CFR§178.345-9 Pumps, piping, hoses and connections.\n(h) Use of a nonmetallic pipe, valve or connection that is not as strong and\nheat resistant as the cargo tank material is authorized only if such\nattachment is located outboard of the lading retention system.\nSpecific requests for interpretation:\n1. 49CFR§178.345-9(h) addresses the material restriction for nonmetallic pipe, valve\nor connection. Does the material restriction mandated by 49CFR§178.345-9(h)\nalso apply to the material used for the body of a pressure relief device such as a\nnormal vent used on a DOT 406 cargo Tank?\n2. Are there any other sections of code that restrict the use of high-performance\n\n<<<PAGE 4>>>\n\nengineered copolymer as the material of construction for a normal vent body for\nuse on DOT 406 cargo tank?\nThank you for your time and consideration.\nBest regards,\nDavid J. Adams\nDirector of Design Engineering\ndadams@bettsind.com\nP 814-723-1250 Ex. 136\nBetts Industries, Inc.\nBetts Industries, Inc.\n1800 Pennsylvania Ave W., Warren, PA 16365\n**** Betts Industries, Inc. Email Notification **** This e-mail is only intended for the person(s) to whom it is addressed and\nmay contain confidential information. Unless stated to the contrary, any opinions or comments are personal to the writer and\ndo not represent the official view of the company. If you have received this e-mail in error, please notify us immediately by\nreply e-mail and then delete this message from your system. Please do not copy it or use it for any purposes, or disclose its\ncontents to any other person. Thank you for your cooperation.","truncated":false,"body_characters":4548}