Interpretation Response #10-0198 ([Smart-Hose Technologies] [Ms. Andrea Guevara])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Smart-Hose Technologies
Individual Name: Ms. Andrea Guevara
Location State: PA Country: US
View the Interpretation Document
Response text:
November 3, 2010
Ms. Andrea Guevara
Smart-Hose Technologies
P.O. Box 16828
Philadelphia, PA 19142
Ref. No.: 10-0198
Dear Mr. Guevara:
This responds to your September 3, 2010 letter requesting clarification of the emergency discharge control requirements for cargo tank motor vehicles (CTMVs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You have attached a guidance document intended to be distributed to your clients for compliance assistance. The guidance document summarizes the passive shut-down requirements in § 173.315(n) and includes a list of materials that would require passive shut-down capability under the HMR. Specifically, you ask confirmation that the list of proper shipping names in your guidance document accurately identifies materials that would require passive shut-down capability under § 173.315(n).
The table in § 173.315(n)(1) specifies emergency discharge control requirements for CTMVs in liquefied compressed gas service. The requirements are specific to the type of material being transported, the type of service (i.e., metered delivery or unmetered delivery), and whether the person attending the unloading operation has an unobstructed view of the cargo tank and delivery hose. PHMSA is supportive of your efforts to list all of the materials and the circumstances that would require a passive shut-down capability in accordance with §§ 173.315(n)(1) and (n)(2) in a single guidance document to assist your clients with compliance. However, it is not PHMSA"s policy to review, approve, or endorse specific guidance documents developed and published by non-government entities.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Ben Supko
Acting Chief, Standards Development
Office of Hazardous Materials Standards
173.315(n)
Regulation Sections
| Section | Subject |
|---|---|
| 173.315 | Compressed gases in cargo tanks and portable tanks |