Interpretation Response #15-0099 ([Girard Equipment, Inc.] [Mr. Glen Harm])

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

Interpretation Response Details

Response Publish Date: 12/15/2015

Company Name: Girard Equipment, Inc.

Individual Name: Mr. Glen Harm

Location State: FL Country: US

View the Interpretation Document

Response text:

December 15, 2015

Mr. Glen Harm
Engineering Manager
Girard Equipment, Inc.
4360 Old Dixie Highway
Vero Beach, FL  32967

Reference No. 15-0099

Dear Mr. Harm:

This is in response to your May 8, 2015 e-mail and letter, and October 23, 2015 telephone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of pressure relief devices (PRDs) for Department of Transportation (DOT) Specification 407 cargo tanks.  

You state your company uses the following marks to identify the four PRD models it manufactures for DOT Specification 407 cargo tanks:  
• DOT 407 Pressure Relief Vent for MAWP 25,
• DOT 407 Pressure Relief Vent for MAWP 30,
• DOT 407 Pressure Relief Vent for MAWP 35, and
• DOT 407 Pressure Relief Vent for MAWP SP (special setting).   

You ask if the model numbers your company marks on the PRDs it manufactures comply with the marking requirements for these devices as prescribed in § 178.345-10(h).

The answer is yes.  The HMR do not define the wording “model number” nor specify what information a model number must contain.  Therefore, it is the opinion of this Office that a model number for a PRD must be sufficiently distinct for a company to distinguish one of its PRD models from another.  It is also the opinion of this Office that the model numbers you provided meet this criterion.  

I hope this satisfies your request.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
178.345-10(h)

Regulation Sections