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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0123 ([Keehn Service Corporation] [Mr. Richard C. Willard])

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

Interpretation Response Details

Response Publish Date:

Company Name: Keehn Service Corporation

Individual Name: Mr. Richard C. Willard

Location State: PA Country: US

View the Interpretation Document

Response text:

May 10, 2000

Mr. Richard C. Willard                Ref. No. 00-0123
Keehn Service Corporation
99 North 11th Avenue
Coatesville, Pennsylvania 19320

Dear Mr. Willard:

This responds to your letter, dated April 18, 2000, concerning certain record keeping requirements applicable to cargo tanks used to transport liquefied compressed gases under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask about the information that will be required to document hose testing conducted by a Registered Inspector in accordance with ' 180.407(h)(4) of the HMR.

As currently written, the language related to record keeping in §180.407(h)(4) is unclear, particularly the reference to the date of the "original hose assembly test." The inclusion of the term Aoriginal@ in this paragraph was inadvertent.  To comply with the record keeping requirements in this paragraph, a Registered Inspector must note the hose identification number of the hose being tested, the date of the test, and the condition of the hose assembly and piping system tested.  We will delete the inadvertent reference to an Aoriginal@ hose assembly test in a future rulemaking.

Section 180.416(b) of the HMR requires operators to assure that each cargo tank delivery hose assembly is permanently marked with a unique identification number and maximum working pressure.  This marking must be applied by July 1, 2000.  In addition, after July 1, 1999, new and repaired hose assemblies must be marked with the month and year that they were pressure tested in accordance with &SEs 178.337-9(b)(7) and 180.416(o). Hose assemblies manufactured or repaired prior to July 1, 1999, will not have this test marking.

You are correct that, after July 1, 2000, operators must maintain written records documenting pressure tests for new and repaired hose assemblies.  The record must include the date of the test, the signature of the inspector, the name of the hose owner, the hose identification number, the date of the original delivery hose assembly and test, notes of any defects observed and repairs made, and an indication that the delivery hose assembly passed or failed the tests or inspections.  For hose assemblies manufactured or repaired prior to July 1, 1999, there will be no date for an original hose assembly test because none was required before this date.  For hose assemblies manufactured after July 1, 1999, the date the hose assembly was manufactured and pressure tested will be marked on the hose and must be entered on the written record documenting any subsequent pressure test.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks