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Interpretation Response #16-0063 ([The Dow Chemical Company] [Mr. John Jeater])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: The Dow Chemical Company

Individual Name: Mr. John Jeater

Location State: PA Country: US

View the Interpretation Document

Response text:

August 2, 2016

Mr. John Heater
Transportation Safety and Security Specialist
The Dow Chemical Company
100 Independence Mall West
Philadelphia, PA  19106

Reference No. 16-0063

Dear Mr. Heater:

This letter is in response to your April 7, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to requirements for the periodic testing, inspection, and repair of portable tanks.  Specifically, you ask whether a United Nations (UN) portable tank may be tested with an inert gas, such as nitrogen, for the leakage test prescribed in § 180.605(h).

The answer is yes.  For the purposes of design and construction of UN portable tanks under subpart H of part 178 of the HMR, the definition of leakage test in § 178.274(a)(3) means a test using gas to subject the shell and its service equipment to an internal pressure.  Thus, an inert gas, such as nitrogen, may be used as a test medium for tests conducted as required by   § 180.605(h).

I hope this information is helpful.  Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
180.605(h), 178.274(a)(3)

Regulation Sections