Interpretation Response #25-0153
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: The National Board of Boiler and Pressure Vessel Inspectors (NBBI)
Individual Name: Luis Ponce
Location State: OH Country: US
View the Interpretation Document
Response text:
May 18, 2026
Mr. Luis Ponce
The National Board of Boiler and Pressure Vessel Inspectors (NBBI)
1055 Crupper Avenue
Columbus, OH 43229-1183
Reference No. 25-0153
Dear Mr. Ponce:
This letter is in response to your November 19, 2025 email requesting clarification on how the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) apply to the repair or modification of specification cargo tanks performed by a repair facility holding a valid National Board Certificate of Authorization for use of the National Board "R" stamp. Specifically, you seek clarification on the applicability of the associated National Board Inspection Code (NBIC).
We have paraphrased and answered your questions as follows:
Q1. Does § 180.413(a)(1) require each repair, modification, stretching, or rebarrelling of a specification cargo tank performed by the repair facility to be performed in accordance with the NBIC, including the application of the "R" symbol stamp and the signing of the applicable Form "R" Report?
A1. No. Section 180.413(a)(1) sets standards for the repair facility performing the work unless otherwise excepted.
Q2. Does § 180.413(a)(1) require each repair, modification, stretching, or rebarrelling of a specification cargo tank be performed in accordance with the edition of the NBIC in effect at the time the work is performed?
A2. In § 180.413(a)(1), the language “in effect at the time the work is performed” refers to the edition of the NBIC incorporated by reference into the HMR at the time the work is performed (see § 171.7(x)(1)). At the time of this writing, that is the 1992 edition. However, there are exceptions in §§ 180.413(a)(1)(i), (ii), and (iii).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division