Interpretation Response #15-0096 ([HazMat Resources, Inc.] [Mr. Danny Shelton])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HazMat Resources, Inc.
Individual Name: Mr. Danny Shelton
Location State: TX Country: US
View the Interpretation Document
Response text:
December 08, 2015
Danny Shelton
President, HazMat Resources, Inc.
124 Rainbow Drive, Suite 2471
Livingston, TX 77399-1024
Ref. No. 15-0096
Dear Mr. Shelton:
This responds to your letter of May 8, 2015 requesting clarification of the marking requirements for pressure relief devices (PRDs) installed on cargo tank motor vehicles (CTMVs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:
Q1. Regarding § 178.345-10(h), may a PRD be marked with a model number comprised generically of the cargo tank specification number and the maximum allowable working pressure (MAWP) (e.g., “DOT 407 PRESSURE VENT FOR MAWP 35”), with knowledge that this model number is used to describe pressure relief devices having certain variations?
A1. Yes. The HMR do not define the term “model number.” Conventional dictionaries can be used to indicate that a “model number” is an identifier for each type of product that a manufacturer makes. Therefore, the marking comprised generically of the cargo tank specification number and MAWP could serve as a model number.
Q2. Do the HMR use the terms “model number” and “part number” interchangeably?
A2. No. The HMR do not use the terms “model number” and “part number” interchangeably. See A1 in regard to the meaning of “model number.” Conventional dictionaries can be used to indicate that a “part number” is an identifier of a particular part design used to reference that part. A “part number” might be used to identify a particular part across a variety of manufacturers or other entities.
Q3. Do the HMR require the PRD to be marked with a single flow rating that is specific to the PRD installed on a given CTMV or do the HMR allow the PRD to be marked with multiple flow ratings?
A3. The HMR do not state that the PRD must be marked with a single flow rating that is specific to the PRD. Thus, the HMR allow for the PRD to be marked with multiple flow ratings based on the conditions of successful flow capacity certification testing and the certification by a responsible official of the device manufacturer as required by 178.345-10(g)(3).
Q4. Do the markings on the PRD identified in the roadside inspection report generated from the State of Ohio meet the requirements of § 178.345-10(h)?
A4. Yes. Based on the documents sent in support of your request, it is the opinion of this Office that these markings appear to meet the requirements of § 178.345-10(h).
Q5. Do the markings on the PRD identified as being manufactured by Betts Industries meet the requirements of § 178.345-10(h)?
A5. Yes. Based on the documents sent in support of your request, it is the opinion of this Office that these markings appear to meet the requirements of § 178.345-10(h).
I hope this answers your inquiry. If you need additional assistance, please contact this Office again.
Sincerely,
Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
178.345-10(h), 178.345-10(g)(3)
Regulation Sections
| Section | Subject |
|---|---|
| 178.345-10 | Pressure relief |
| 178.345-10 | Pressure relief |