Interpretation Response #14-0196 ([Lamb Fuels, Inc.] [Mr. Jeff Lisowski])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Lamb Fuels, Inc.
Individual Name: Mr. Jeff Lisowski
Location State: CA Country: US
View the Interpretation Document
Response text:
Jeff Lisowski
Safety and Compliance Manager
Lamb Fuels, Inc.
725 Main Street, Suite B
Chula Vista, CA 91911
Ref. No. 14-0196
Dear Mr. Lisowski:
This responds to your request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the specification marking on a MC 306 cargo tank. Specifically, you ask whether the specification data plate on a MC 306 cargo tank built in the 1970s should be located on the front right side of the cargo tank in accordance with the regulations at the time of construction of the cargo tank.
Your understanding is correct. When a cargo tank specification is removed from the HMR, new construction is no longer authorized. Section 180.405 allows for the continued use of existing MC 306 cargo tanks built prior to the removal of their specification. Except as otherwise provided in § 180.405, to qualify as an authorized packaging, MC 306 cargo tanks must fully conform to the applicable specification in effect on the date initial construction began. Between 1968 and July 1, 1985 the metal specification plate was required to be located on the "right side, near the front, in a place readily accessible for inspection" in accordance with § 178.340-10(b).
I hope this information is helpful. If you have further questions, please contact this office.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division
180.405, 178.340-10(b)
Regulation Sections
| Section | Subject |
|---|---|
| 180.405 | Qualification of cargo tanks |