Interpretation Response #00-0079 ([Trinity Industries, Inc.] [Mr. Greg McRae])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Trinity Industries, Inc.
Individual Name: Mr. Greg McRae
Location State: TX Country: US
View the Interpretation Document
Response text:
March 28, 2000
Mr. Greg McRae, Quality Assurance Ref. No. 00-0079
Trinity Industries, Inc.
P.O. Box 588887
Dallas, TX 75358
Dear Mr. McRae:
This is in reference to your letter addressed to Mr. Charles Hochman, Office of Hazardous Materials Technology, concerning specification shortages on a cargo tank manufactured to the MC 331 specification. You inquired whether your company may manufacture the cargo tank only and stamp "MC 331" on the metal identification plate. The assembler (i.e., cargo tank motor vehicle manufacturer) would stamp the original test date on the identification plate after all other specification requirements have been met.
The answer is yes, the identification plate may be stamped with the specification number. For the MC 331 specification, the cargo tank is an ASME Code "U" stamped tank fitted with all appurtenances, reinforcements, fittings, and closures affecting lading retention installed by the cargo tank manufacturer. See definition of "cargo tank" in 49 CFR 178.320. The MC 331 specification in §178.337 does not preclude the manufacture of a cargo tank motor vehicle in stages with the work performed by different manufacturers. Marking the original test date and the specification number on a cargo tank's metal identification plate certifies that the cargo tank conforms to the applicable specification.
Your company must provide the ASME manufacturer's data report and related documents to the cargo tank motor vehicle manufacturer. The certificate of compliance stating that the completed cargo tank motor vehicle conforms in all respects to the MC 331 specification would be completed by the cargo tank motor vehicle manufacturer, as specified in §178.337-18. The registration numbers of the manufacturer, the Design Certifying Engineer and the Registered Inspector, as appropriate, must appear on the certificates.
I hope this information is helpful. If I can be of further assistance, please contact me.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
178.345-15
Regulation Sections
| Section | Subject |
|---|---|
| 178.345-15 | Certification |