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Interpretation Response #02-0236 ([Browning Bushman P.C] [Loren G. Helmreich])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Browning Bushman P.C

Individual Name: Loren G. Helmreich

Location State: TX Country: US

View the Interpretation Document

Response text:

Dec 11 2002

Mr. Loren G. Helmreich                    Reference No. 02-0236
Browning Bushman P.C.
5718 Westheimer
Suite 1800
Houston, TX 77057-5771

Dear Mr. Helmreich:

This is in response to your August 29, 2002,letter regarding automatic shut off devices on cargo tanks under § 173.315 in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a shut off system that is certified by a Design Certified Engineer per § 173.315(n)(2)(ii) and installed in the hose must be installed under the supervision of a Registered Inspector as per § 173.315(n)(2)(iii).

The answer is yes.  The device you describe requires modifications to a hose beyond regular operation as that term is used in § 173.315(n)(2)(iii). Therefore, the shutoff device must be installed under the supervision of a Registered Inspector.  Once installed in the hose, however, the hose may be attached and unattached from the cargo tank without supervision.

I hope this satisfies your request.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

173.315

Regulation Sections