Interpretation Response #04-0007 ([Peldev] [Mr. D.E. Williams])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Peldev
Individual Name: Mr. D.E. Williams
Country: ZA
View the Interpretation Document
Response text:
Nov 23, 2004
Mr. D.E. Williams Reference No. 04-0007
Chief Technologist: Specialist & Consultants
Peldev
P.O. Box 582
Pretoria, 0001
Dear Mr. Williams:
This is in response to your letter requesting clarification of the Hazardous Materials Regulation (HMR; 49 CFR Parts 171-180) applicable to the periodic inspection and testing of specification DOT 51 portable tanks under § 180.605. We apologize for the delay and hope it has not caused you any inconvenience. Specifically, you asked if a DOT 51 specification portable tank may be periodically inspected and tested by a third party or accredited testing station since there are no DOT approved testing stations in South Africa other than the South African Airways.
The answer to your question is yes. Either of the test agencies described in your letter may perform the periodic retest requirements for DOT Specification 51 portable tanks. The requalification requirement in § 180.605 (c)(2) specifies a five year test interval, but there is no requirement for such test to be performed by an approved third party testing agency. The tank owner or user may have the tank inspected and tested by any qualified tester of his or her choosing.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
178.245, 180.605