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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 #00-0382 ([Federal Motor Carrier Safety Administration] [Stephen E. Barber])

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

Interpretation Response Details

Response Publish Date:

Company Name: Federal Motor Carrier Safety Administration

Individual Name: Stephen E. Barber

Location State: DC Country: US

View the Interpretation Document

Response text:

Date:    APR 6, 2000                     Reply to Attn. of:    Gorsky, x69532

Subject:     Request for Interpretation

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

To:    Stephen E. Barber

Acting Director of Enforcement and Compliance


Federal Motor Carrier Safety Administration

This responds to your request for an interpretation, dated March 27, 2000, of 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.

You are correct that, 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 "original" 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 "original" hose assembly test in a future rulemaking.

Your understanding of the hose marking requirements is correct. 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 §§ 178.337-9(b)(7) and 180.416(f). Hose assemblies manufactured or repaired prior to July 1, 1999, will not have this test marking.

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

180.407

Regulation Sections

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