Interpretation Response #07-0194 ([HAZMATEAM, Inc.] [Mr. Paul J. Dambek])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HAZMATEAM, Inc.
Individual Name: Mr. Paul J. Dambek
Location State: NH Country: US
View the Interpretation Document
Response text:
February 14, 2008
Mr. Paul J. Dambek
HAZMATEAM, Inc.
12 Kimball Hill Road
Hudson, NH 03051-3915
Ref. No. 07-0194
Dear Mr. Dambek:
This is in response to your September 26, 2007 letter regarding portable tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
You state your client transports UN 1921 "Propyleneimine, stabilized, 3, 6.1, PGI" in portable tanks certified in Europe to "T19" criteria per ADR/RID/IMDG standards. You submitted copies of the inspection certificates for our review. Your client wants to use the portable tanks to transport the product by motor vehicle in the United States. Your questions are paraphrased and addressed as follows:
Q1. Would a portable tank meeting the "T14" and/or "T19" criteria in the ADR/RID/IMDG standards also meet the "T14" and/or "T19" criteria in the HMR?
A1. Yes. The criteria specified for the Codes "T14" and "T19" in the HMR are consistent with the criteria specified for these Codes in the UN Recommendations on the Transport of Dangerous Goods and the International Maritime Dangerous Goods (IMDG) Code.
Q2. Does the HMR allow a portable tank authorized to the "T19" criteria to be used to transport a hazardous material requiring a "T14" authorization?
A2. Yes. The criteria specified for these T Codes ("T19" and "T14") are identical with the exception that the minimum test pressure is specified at 6 bar for Code "T14" and 10 bar for Code "T19." Section 172.102(c)(7)(v)(A) provides that when a portable tank is specified by a "T" Code in Column (7) of the § 172.101 Hazardous Materials Table for a specific hazardous material, a specification portable tank conforming to an alternative tank instruction may be used if the alternative portable tank has a higher or equivalent test pressure.
Q3. Would the six (6) portable tanks specified in the accompanying inspection certificates be allowed to transport "Propyleneimine, stabilized" in the United States without further approval or testing?
A3. Provided they are certified and marked as UN portable tanks, the six (6) portable tanks specified in the accompanying inspection certificates would be allowed to transport "Propyleneimine, stabilized" in the United States without further approval or testing (See § 171.25(c) of the HMR.)
I hope this information is helpful.
Sincerely,
John A. Gale,
Chief, Standards Development
Office of Hazardous Materials Standards
172.102 (c) (7)(A), 171.25(c)