{"operation":"document","citation":"25-0136","title":"Linde Gas and Equipment — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2026-02-24","effective_on":null,"summary":"25-0136 response to Linde Gas and Equipment concerning 180.417.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0136.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0136.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0136","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2026-02/25-0136.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nFebruary 24, 2026\nMark Hammond\nLinde Gas and Equipment\n3625 S. Main Street\nSouth Bend, IN 46614\nReference No. 25-0136\nDear Mr. Hammond:\nThis letter is in response to your October 8, 2025 email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to leakage\ntesting on cargo tanks. You perform annual visual and leakage inspections on cargo tanks\ncontaining liquefied petroleum gas (LPG) in which you apply a leak-detecting fluid to find\nbubbles at fittings, valves, and welds. You ask about a test and inspection form that your\ncompany uses to record requalification activity. The form includes a section to record\nperformance of a leakage test and two boxes to indicate a “hydrostatic” or “pneumatic” test.\nThe report contains an additional section to indicate performance of a leakage test which\nincludes fields to indicate the fluid used and pressure during a leakage test. Specifically, you\nask whether you should leave both the hydrostatic or pneumatic boxes blank and instead fill\nout the second leakage test portion of the form with LPG listed as the test medium (i.e., the\nfluid used).\nThe HMR neither requires use of a particular form nor specifies a format. Therefore, this\nOffice cannot provide specific instructions regarding how to fill out the proprietary form you\nprovided and described in your letter. You need only record and maintain a report of tests or\ninspections in accordance with § 180.417(b).\nHowever, it is the opinion of this Office that not selecting either “hydrostatic” or\n“pneumatic” when recording a leakage test is appropriate. Pneumatic and hydrostatic tests are\n“pressure tests” as specified in 49 CFR 180.407(g). The inspection method you described\nconforms to the “leakage test” outlined in 49 CFR § 180.407(h), therefore you should only\nrecord the completion of a leakage test. Furthermore, this Office suggests that the second\nportion of the form should also remain blank unless you are providing information related to\n1200 New Jersey Avenue, SE\nWashington, DC 20590\n\n<<>>\n\nEnvironmental Protection Agency (EPA) Method 27 Vapor Tightness Test (K-\nEPA27).\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<<>>\n\nCasey, C.\n25-0136\nFrom: INFOCNTR (PHMSA)\nTo: Baker, Yul (PHMSA)\nCc: Hazmat Interps\nSubject: FW: Letter Of Interpretation Request\nDate: Wednesday, October 8, 2025 16:43:07\nAttachments: JJ Keller Inspection Report.pdf\nGood afternoon,\nPlease see the following request for a letter of interpretation. Please let us know if you need\nanything.\nBest,\nAminah\nFrom: Mark A Hammond \nSent: Wednesday, October 8, 2025 5:58 AM\nTo: INFOCNTR (PHMSA) \nSubject: Letter Of Interpretation Request\nYou don't often get email from mark.a.hammond@linde.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.\nGood morning. I have a concern regarding the use of the JJ Keller Tanker Test and Inspection\nReport (Please see attachment and highlighted areas). I conduct annual Visual and Leak tests\nonly. In the area of the form “Type of Tests – Leakage Test (K)” the form gives a choice of\nHydrostatic (water) and Pneumatic (air). While conducting an inspection on a Propane bobtail\nneither one of these seems appropriate for a flammable gas. Would the best approach be to\nleave the 2 choices, hydrostatic or pneumatic, blank and mark fluid used (which I always do) in\nthe “Leakage Test” box (also highlighted under the K-EPA27 and Upper Coupler Assembly\nboxes)?\nI have attached email communication with Jessica Stiles DOT Hazardous Materials Program\nManager on this same question from 9-9-25.\nThank you.\nMark Hammond\nLinde Gas and Equipment\n574-210-5992\n3625 S Main Street South Bend, Indiana 46614\n\n<<>>\n\nFrom: Stiles, Jessica (FMCSA) \nSent: Wednesday, September 17, 2025 9:35 AM\nTo: Mark A Hammond \nCc: Rios, David (FMCSA) \nSubject: RE: JJ Keller Tank Inspection Form\nCYBERSECURITY ALERT: This is an email from an external organization. Use caution, especially with\nlinks and attachments. More\nHi again Mark. After consultation with PHMSA, we all agree that for a leakage test/inspection\nreport there is no need to list whether it was pneumatic or hydrostatic, since those two terms\nare not used in 49 CFR 180.407(h).\nHowever, those two terms are used in the pressure testing section of the regulation (49 CFR\n180.407(g)) so you’ll need to be sure to include hydrostatic or pneumatic when a pressure test\nreport is completed.\nSection 49 CFR 180.417(b)(2)(iii) also requires that the leakage test report include:\nidentification of the fluid used for the test, test pressure, and holding time of test. So while you\ndon’t need to list pneumatic or hydrostatic, you do still have to include these three items along\nwith all the other information required by 180.417(b). You are correct that for the “fluid used”\nyou can list LPG as the medium if that’s what was used for the test.\nThank you,\nJessica Stiles\nHazardous Materials Program Manager\nMidwestern Service Center\n360-846-3869\nFrom: Mark A Hammond \nSent: Tuesday, September 16, 2025 4:30 AM\nTo: Stiles, Jessica (FMCSA) \nCc: Rios, David (FMCSA) \nSubject: RE: JJ Keller Tank Inspection Form\nYou don't often get email from mark.a.hammond@linde.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.\nThank you, Jessica.\n\n<<>>\n\nFrom: Stiles, Jessica (FMCSA) \nSent: Monday, September 15, 2025 11:12 AM\nTo: Mark A Hammond \nCc: Rios, David (FMCSA) \nSubject: RE: JJ Keller Tank Inspection Form\nCYBERSECURITY ALERT: This is an email from an external organization. Use caution, especially with\nlinks and attachments. More\nGood morning Mark.\nMy apologies – I’m not ignoring this email, but your question made me reevaluate how I’ve read this\nregulation for years. I’ve reached out to PHMSA to get their take on it and will let you know once I\nhear back.\nThank you,\nJessica Stiles\nHazardous Materials Program Manager\nMidwestern Service Center\n360-846-3869\nFrom: Mark A Hammond \nSent: Tuesday, September 9, 2025 6:15 AM\nTo: Stiles, Jessica (FMCSA) ; Rios, David (FMCSA) \nSubject: JJ Keller Tank Inspection Form\nSome people who received this message don't often get email from mark.a.hammond@linde.com. Learn why this\nis 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.\nGood morning. I have a question regarding the Leakage Test (Under heading “Type of Tests”)\non the form. There is Hydrostatic (water test?) and Pneumatic (air or inert gas?). When\nconducting an inspection on a propane bobtail neither description seems to be correct.\nShould I leave the 2 choices (Hydrostatic or Pneumatic) blank and fill out the other Leakage\nTest area circled about half way down the form on the right side with Liquid Propane noted as\nthe test medium?\nThank you.\nThe information contained in this email and any attachments may be confidential and is\nprovided solely for the use of the intended recipient(s). If you are not the intended\nrecipient, you are hereby notified that any disclosure, distribution, or use of this e-mail,\n\n<<>>\n\nits attachments or any information contained therein is unauthorized and prohibited. If\nyou have received this in error, please contact the sender immediately and delete this e-\nmail and any attachments. No responsibility is accepted for any virus or defect that\nmight arise from opening this e-mail or attachments, whether or not it has been checked\nby anti-virus software.\nThe information contained in this email and any attachments may be confidential and is\nprovided solely for the use of the intended recipient(s). If you are not the intended\nrecipient, you are hereby notified that any disclosure, distribution, or use of this e-mail,\nits attachments or any information contained therein is unauthorized and prohibited. If\nyou have received this in error, please contact the sender immediately and delete this e-\nmail and any attachments. No responsibility is accepted for any virus or defect that\nmight arise from opening this e-mail or attachments, whether or not it has been checked\nby anti-virus software.\nThe information contained in this email and any attachments may be confidential and is\nprovided solely for the use of the intended recipient(s). If you are not the intended\nrecipient, you are hereby notified that any disclosure, distribution, or use of this e-mail,\nits attachments or any information contained therein is unauthorized and prohibited. If\nyou have received this in error, please contact the sender immediately and delete this e-\nmail and any attachments. No responsibility is accepted for any virus or defect that\nmight arise from opening this e-mail or attachments, whether or not it has been checked\nby anti-virus software.\n\n<<>>\n\n_ AVERAGE\nPRESSURE TEST\nREPORT NUMBER\nREPAIR DATE\n8898 (Rev. 1/17)\nTELEPHONE\nEND\nASME CODE SYMBOL\nDATE\nMAXIMUM ALLOWABLE WORKING PRESSURE\nMEASUrE\nMANUFACTURER'S TANK SERIAL NO.\nK-EPA27\nGasoline Delivery Tank Pressure Test -\nEPA Reference Method 27\nSTART\nVESSEL MATERIAL SPEC. NO.\nUPPER COUPLER ASSEMBLY\nWATER CAPACITY IN LBS.\n• REMOVED FOR EXAMINATION\nLEAKAGE TEST\nASME OR NATIONAL BOARD NO. OF REPAIR FACILITY\nEND\n• EXAMINED IN PLACE\nMARKINGS APPLIED: • YES • NO\n• delivery hose/piping • appurtenances\n• NO\nPSIG\nSTART |\nSTRESS RELIEVED AFTER FABRICATION\nFLUID CAPACITY (GALS.)\nTANK\n• INSULATED\nFLUID USED\nPRESSURE\nHOLDING TIME\nPRES\nRES\nVENT\nDESIGN CERTIFYING ENGINEER REGISTRATION NO.\n• YES\n• DEFECTS OR DAMAGE DISCOVERED\nTANK IDENTIFICATION NO. INSPECTION TEST DATE\n• MATERIAL CORROSIVE TO TANK\n• DEDICATED SERVICE\nSIGNATURE OF OWNER\nPRINCIPAL PLACE OF BUSINESS ADDRESS\nSPECIAL SERVICE\n• OTHER\nMIN. TESTED\nLINED\nTYPE\n(• Full • Local) • NO\nCARRIER (if other than owner)\nCITY, STATE, ZIP CODE\nCARRIER'S EQUIPMENT NO.\nSTRESS RELIEVED AFTER REPAIR\nTANK MANUFACTURER\nDOT SPECIFICATION NO.\nORIGINAL TEST DATE\nDESIGN TEMPERATURE\n• YES\nREPAIRED BY\nADDRESS\nCITY, STATE, ZIP\nMFG,\nITEMS INSPECTED OR TESTED\nDATE\nORIGINAL\nPressure - set to discharge\nSHELL BOTTOM\nIS REPAIR CERTIFICATION REQUIRED? • YES • NO\nTELEPHONE\n• PRESSURE RETEST (P)\nPressure - when open\nPressure - when reseated\nTHICKNESS (INCHES)\nCARGO TANK: • MEETS • FAILS TO MEET THE REQUIREMENTS OF THE DOT SPECIFICATIONS IDENTIFIED ON THIS REPORT\n• WITHDRAWN FROM SERVICE • RETURNED TO SERVICE\nMFG. DATE\nDESIGN TEMPERATURE\n• HYDROSTATIC\n• PNEUMATIC\nPRESSURE\nDevice Number\nTested\nRemoved\nInspected\nReplaced\nReinstalled\nHEAD\nSHELL TOP\nSHELL SIDE\nRELIEF\nDEVICES\nRepaired\nTEST DATE\nDOT REGISTRATION NUMBER\nCARGO TANK MOTOR VEHICLE CERT. DATE\nMAX. DESIGN DENSITY OF LADING\n• NO DEFECT OR DAMAGE DISCOVERED\n(LBS. PER GAL.)\n• PNEUMATIC\nITEM\n• suspension system\nconnecting structures\nPressure Bearing Portions\nattachments\nLining Material\nof Heating System\nFlues for Heating System\nCorroded or Abraded Areas\n(• CERTIFIED AS 0.2% WATER BY WEIGHT)\nMATERIAL\nHEAD\nFrangible (Rupture) Disk\nMajor Appurtenances\nupper coupler assembly\nTYPE OF TEST(S)\n• ANHYDROUS AMMONIA\n• LIQUEFIED PETROLEUM GAS\nTANKER TEST AND INSPECTION REPORT\nLINING MATERIALS\n• DELIVERY HOSE/PIPING\nDistortions\nDESIGN PRESSURE\nDents\nWelds\n• LEAKAGE TEST (K)\n• HYDROSTATIC\nFor compliance with 49 CFR 180.407(h)(4), 180.417(b) & (c), and 40 CFR 60.505(b)\n(PSIG)\n• K-EPA27\nYES NO\nDATE OF ORIG. HOSE\nDELIVERY HOSE/PIPING\nASSEMBLY TEST.\nLOCATION OF DEFECTS OR DAMAGE: • weld • heat-affected zone\nDOT REGISTRATION NUMBER OF THE TESTING FACILITY/PERSON\nNeenah, WI • JJKeller.com • (800) 327-6868 • Printed in the USA\nPRINCIPAL PLACE OF BUSINESS ADDRESS\nCARGO TANK MOTOR VEHICLE MFG.\nEXPOSED SURFACE AREA IN SQ. FT.\nITEM\nHead-to-Shell Seam\nTank Shell\nTank Heads\nManhole Covers\nManhole Gaskets\nDevices for Tightening\nGaskets on Full Opening\nSelf-closing Stop-valves\nExcess Flow Valves\nRemote Closure Devices\nCITY, STATE, ZIP CODE\nOWNER'S TANK SERIAL NO.\nMAX. WEIGHT OF LADING\n] EXTERNAL VISUAL (V)\n• INTERNAL VISUAL (1)|\nO LINING INSPECTION (L)\nReclosing Pressure\nCONDITION OF HOSE ASSEMBLY\nDISPOSITION OF CARGO TANK:\nSIGNATURE OF INSPECTOR / TESTER\nCopyright 2017 J. J. Keller & Associates, Inc.\n• THICKNESS TEST (T)\nValves\nGaskets\nManhole\nRear Head\nRelief Valves\nNuts and Bolts\n& PIPING SYSTEM\nNATURE AND SEVERITY:\nMETHOD OF REPAIRS:\nTESTED BY (Person's Name)\nOWNER\nHEATING\nSYSTEM\nTHIS UNIT\nHAS HAULED\nSHELL\nHOSE\nI.D. NO. _\nADDRESS\nCITY, STATE, ZIP","truncated":false,"body_characters":13265}