Interpretation Response #12-0254 ([Poly-Coat Systems, Inc.] [Ms. Suzanne Felix])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Poly-Coat Systems, Inc.
Individual Name: Ms. Suzanne Felix
Location State: TX Country: US
View the Interpretation Document
Response text:
February 28, 2013
Ms. Suzanne Felix
Corporate Secretary
Poly-Coat Systems, Inc.
501 Liverpool Spur
Liverpool, TX 77577
Ref. No.: 12-0254
Dear Ms. Felix:
This is in response to your November 08, 2012 email requesting clarification of the requirements for application of the "L" decal on non-DOT specification glass fiber reinforced plastic (GFRP) DOT-407 and 412 equivalent special permit tankers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if an "L" marking should be applied to non-DOT specification GFRP DOT-407 and 412 equivalent tankers operating under special permit.
Your email does not reference any specific special permits. However, the lining inspection requirements of § 180.407(f) do not apply if cargo tanks are authorized by the special permit they are operating under to be manufactured and utilized in transportation without a liner.
Test and inspection marking requirements for cargo tanks are provided in § 180.415. Section 180.415(a) requires each cargo tank successfully completing the test and inspection requirements contained in § 180.407 to be marked as specified in the rest of that section; to include an "L" marking for lining inspections. If no liner is present in a cargo tank operating under a special permit, no lining inspection is required and no marking in accordance with § 180.415 is required.
Unless otherwise provided for by special permit, any cargo tank utilizing a liner is subject to the lining inspection requirements of § 180.407(f) and subsequently the marking requirements in § 180.415(b).
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
180.407, 180.415