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Interpretation Response #03-0035 ([Riddick Engineering Corporation] [Mr. Chris J. Teas, PE])

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

Interpretation Response Details

Response Publish Date:

Company Name: Riddick Engineering Corporation

Individual Name: Mr. Chris J. Teas, PE

Location State: AR Country: US

View the Interpretation Document

Response text:

Jul 8, 2003

 

Mr. Chris J. Teas, PE                Reference No. 03-0035
Vice President
Riddick Engineering Corporation
4600 West Markham
Little Rock, AR 72205

Dear Mr. Teas:

This is in response to your letter dated February 11, 2003, and subsequent telephone conversation with Sandra Webb of my staff, requesting clarification of requirements for construction and certification of DOT 407 cargo tanks designed to be loaded by vacuum under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether a cargo vacuum tank must be designed and manufactured with full ASME certification as provided in § 178.347-1(c) or to the provisions outlined in § 178.347-1 (d).  You also ask if, when manufacturing under the provision § 178.347-1(d), the manufacturer is required to be ASME certified as provided in § 107.503(b).

Section 178.347-1(c) provides specific requirements for designing and constructing DOT 407 cargo tanks that are loaded by vacuum.  Specifically it states, “Any cargo tank built to this specification with a MAWP greater than 35 psig and each tank designed to be loaded by vacuum must be constructed and certified in accordance with the ASME Code.  The external design pressure for a cargo tank loaded by vacuum must be at least 15 psig.” Therefore, a cargo tank designed to be loaded by vacuum must be constructed and certified in accordance with the ASME Code.  Additionally, in accordance with § 178.345-1(d) a manufacturer of a cargo tank is required to hold a current ASME certificate of authorization and must be registered with the Department in accordance with 49 CFR part 107 subpart F. This requirement applies if a cargo tank is designed and constructed under §178.347-1(c) or § 178.347-1(d).

I hope this information is helpful. If we can be of further assistance, please do not hesitate to contact us.

Sincerely,
                       

 

Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

178.347

Regulation Sections