Interpretation Response #12-0145 ([HazMat Resources Inc.] [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: Danny Shelton
Location State: TX Country: US
View the Interpretation Document
Response text:
Danny Shelton
HazMat Resources Inc.
124 Rainbow Drive# 2471
Livingston, TX 77399
Reference No.: 12-0145
Dear Mr. Shelton:
Nov 19 2012
This is in response to your July 02, 2012 email requesting guidance regarding the proper method for cargo tank manufacturers to use to restrict an MC331 cargo tank from transporting certain products under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask for help determining proper methods for cargo tank manufacturers to use in order to restrict an MC331 cargo tank from transporting certain products and if the current practice of noting these restrictions in the remarks section of an American Society of Mechanical Engineers (ASME) U1A form is an acceptable way of conveying these restrictions to cargo tank purchasers.
The HMR does not indicate a way to note manufacturer imposed, or buyer requested restrictions on what commodities can be carried in a MC331 cargo tank. Generally speaking, if a tank manufacturer designs, constructs, certifies, and stamps an MC331 cargo tank to ASME Section VIII standards, the cargo tank is appropriate to transport all materials authorized for that specification unless limited by special provisions. Nothing prohibits cargo tank manufactures from indicating commodity carriage restrictions on an ASME U1A form, but no reference is made to such notation in the HMR or in Section VIII of the ASME Code. Please note that it remains the responsibility of the person offering the hazardous material to ensure compatibility with the packaging that is being used.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division