Interpretation Response #01-0203 ([Federal Motor Carrier Safety Administration] [William Quade])
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: William Quade
Country: US
View the Interpretation Document
Response text:
Date: AUG 16, 2001 Reply to Attn of Gorsky, x69532 Ref. No. 01-0203
Subject: Pressure Testing of Cargo Tanks
From: Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards
To: William Quade
Chief of Hazardous Materials Division
Federal Motor Carrier Safety Administration
This responds to your e-mailed request for interpretation, dated August 1,2001, asking for clarification of requirements for periodic pressure testing of cargo tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the reference to an "upper coupler (fifth wheel) assembly" in paragraphs (d)(2)(viii) and (g)(1)(iii) of § 180.407 also includes a turntable, which is a method of permanently attaching a steering axle to the front of a full trailer.
The answer is yes. The turntable performs the same function as a fifth wheel, allowing the pivoting movement between the steering axle and the frame of the cargo tank. This movement causes stress to the cargo tank. Further, the turntable attachment does not allow easy visual inspection of the area of the cargo tank that is directly above the turntable. Therefore, in accordance with § 180.407(d)(2)(viii), as part of an external visual inspection, those elements of a turntable attachment that can be inspected without dismantling the turntable must be examined for corrosion or damage that might prevent safe operation. Additionally, in accordance with § 180.407(g)(1 ) (iii), as part of a pressure test, a turntable attachment must be removed from the cargo tank, and cargo tank areas covered by the turntable attachment must be inspected for corroded and abraded areas, dents, distortions, defects in welds, and any other condition that might render the cargo tank unsafe for transportation.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
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