Interpretation Response #00-0277 ([Design Certifying Engineer] [Mr. David Fellows])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Design Certifying Engineer
Individual Name: Mr. David Fellows
Location State: WI Country: US
View the Interpretation Document
Response text:
October 27, 2000
Mr. David Fellows Reference No. 00-0277
Design Certifying Engineer
904 Hawks Hollow
Delafield, Wisconsin 53018
Dear Mr. Fellows:
This responds to your letter, dated September 20, 2000, concerning installation of a non-metallic packing gland in the bulkhead of a specification cargo tank under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-ISO). You provided two news articles about cargo tanks manufactured with internal agitation systems that utilize Us design feature.
As you noted in your July 5, 2000 letter on this subject, the HMR do not specifically pro a design modification of the type described in the articles. However, if a non-metallic seal or packing gland is utilized, it must be as strong and heat resistant as the material used for construction of the cargo tank (see § 178.345-9(h)). It is not clear from the information you provided that the cargo tanks described conform to this requirement. The Federal Motor Carrier Safety Administration intends to investigate further with cargo tank manufacturers and operators to ascertain whether these cargo tanks conform to HMR specification requirements and, if not, to advise manufacturers and operators on options for achieving compliance with the HMR.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards
178.345