Manchester Tank — Hazardous Materials Safety Interpretation

Page 1• of Transportation U.S. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Special Programs Administration DEC 3 | 1997 Mr. Randy Wahl Director of Technical Development Manchester Tank 1749 Mallory Lane #400 Brentwood, TN 37027 Dear Mr. Wahl: This is in response to your letter requesting clarification of inspection report requirements in 49 CFR 178.35. Specifically, you ask whether your current Inspector's Report is acceptable after October 1, 1997, since the report currently contains at least the minimum information required in._ the Compresses Gas Association (CGA) Pamphlet C-11. The answer is yes. Section 178.35(g) specifies that each report must contain, at a minimum, the applicable information listed in CGA Pamphlet C-11. I hope this information is helpful. Should you have further questions, do not hesitate to contact us. Sincerely, Hate 2 mitchell Hattie L. Mitchell, Chief Exemption and Regulations Termination Office of Hazardous Materials Standards ..-#

Page 2Bette File: 178.35 SC: 33%, August 18, 1997 Mr. Edward T. Mazullo Director of Office of Hazardous Materials Standards U.S. Department of Transportation 4007* Street S.W. Washington, D.C. 20590 Dear Mr. Mazullo: Manchester Tank & Equipment Company would like to request a clarification for 49CFR - Section 178.35 (g). It is our interpretation that our current Inspector's Report format will be acceptable atter Uctober 1, 1997, since the report currently contains at least the minimum information required in CGA Pamphlet C-11. Manchester has put forth considerable cost and effort towards having custom software written to the current report format and would like to avoid having the programs being re-written if at all possible. Manchester Tank would greatly appreciate a written confirmation of our interpretation for our files. Thank you. Sincerely, Randy Wall fee Randy Wahl Director of Technical Development RW:ms CC: Jerry Stockinger Tom Freeland MANCHESTER 1749 Mallory Lane, #400, Brentwood, TN 37027 • (615) 370-3833 • Fax (615) 370-6150#

Page 3MANCHESTER (.. 1749 Mallory Lane, #400, Brentwood, TN 37027 8 M DHM-1O Mr. Edward T. Mazulio Director of Office of Hazardous Materials Standards U.S. Department of Transportation 400 7th Street S.W. Washington, D.C. 20590#