Interpretation Response #18-0099
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Lloyd Register
Individual Name:
Location City: Sassenage Country: FR
View the Interpretation Document
Response text:
March 01, 2019
Thomas Curey
Lloyd’s Register
2, rue de Clémencière, BP 15
38360 Sassenage, France
Reference No. 18-0099
Dear Mr. Curey:
This letter is in response to your July 5, 2018, email and subsequent phone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to United Nations (UN) portable tank design specifications. Your letter referenced language in § 178.274(b)(1) that states, “Aluminum may not be used as a construction material for the shells of portable tanks intended for the transport of non-refrigerated liquefied gases. For portable tanks intended for the transport of liquid or solid hazardous materials, aluminum may only be used as a construction material for portable tank shells if approved by the Associate Administrator.” You ask if aluminum may be used in UN portable tanks designed for the transport of refrigerated liquefied gases without the approval of the Associate Administrator.
The answer is yes. The intent of the language in § 178.274(b)(1) is to allow aluminum in the construction of portable tank shells intended for the transport of refrigerated liquefied gases and does not require approval from the Associate Administrator. PHMSA will consider clarifying this issue in a future rulemaking.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division
178.274(b)(1)
Regulation Sections
| Section | Subject |
|---|---|
| 178.274 | Specifications for UN portable tanks |