Interpretation Response #09-0180 ([Burdette & Associates, Inc.] [Mr. Michael Burdette])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Burdette & Associates, Inc.
Individual Name: Mr. Michael Burdette
Location State: LA Country: US
View the Interpretation Document
Response text:
June 7, 2010
Mr. Michael Burdette
Burdette & Associates, Inc.
P.O. Box 264
Milton, LA 70558
Ref. No.: 09"0180
Dear Mr. Burdette:
This responds to your August 4, 2009 letter regarding the IM and UN portable tank periodic requalification requirements for the Hazardous Materials Regulations (HMR; 49 CFR Parts 171"180). Specifically, you ask whether an approval agency must witness the leakage test required by § 180.605(e) and (h).
The answer is no. There is no requirement in § 180.605(e) and (h) for the leakage test to be performed or witnessed by an approval agency. The tank owner or user may have the tank inspected and tested by any qualified tester including an approved third party testing agency, as long as the qualified testers are trained in accordance with the HMR.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
180.605(e) and (h)