Interpretation Response #07-0069 ([Manager Transportation Regulations and Security] [Mr. Mark Connolly ])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Manager Transportation Regulations and Security
Individual Name: Mr. Mark Connolly
Location State: IL Country: US
View the Interpretation Document
Response text:
Apr 27, 2007
Mr. Mark Connolly Reference No. 07-0069
Manager Transportation Regulations and Security
Akzo Nobel Chemicals Inc
300 South Riverside Plaza
Chicago, IL 60606-6697
Dear Mr. Connolly:
This is in response to your March 23, 2007 letter regarding the schedule for the periodic inspection and test of IM and UN portable tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter you describe a scenario in which the initial inspection and test before the portable tank was put into service was performed in May of 2002 and the intermediate periodic test and inspection (requalification) was performed in September of 2004; that is, two months early. You ask if an additional intermediate periodic requalification must be performed in March of 2007; that is, two months prior to the 5-year periodic requalification.
The answer is no. In accordance with § 180.605(c)(1), an intermediate periodic requalification must be performed at least 2.5 years following the initial inspection and thereafter every 2.5 years following the 5-year periodic requalification. It was our intention to align the periodic requalification schedule contained in the HMR with that contained in the United Nations’ Recommendations on the Transport of Dangerous Goods. Paragraph 6.7.2.19 of the UN Recommendations provides for the 2.5-year intermediate periodic requalification to be performed within 3 months of the specified date. We take a similar position in this matter. Therefore, in the scenario described in your letter, the next required inspection and test, the 5- year periodic requalification, is due May 2007.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
180.605 (c)(1)