Interpretation Response #03-0217 ([Southern International, Incorporated] [Mr. Terry L. Brittenham])

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

Interpretation Response Details

Response Publish Date: 12/19/2003

Company Name: Southern International, Incorporated

Individual Name: Mr. Terry L. Brittenham

Location State: OK Country: US

View the Interpretation Document

Response text:

Dec 19, 2003

Mr. Terry L. Brittenham, President               Reference No. 03-0217

Southern International, Incorporated

4200 Perimeter Center Drive, Suite 205

Oklahoma City, OK 73112-2391

Dear Mr. Brittenham:

This responds to your August 18, 2003, letter requesting clarification concerning requirements for manholes, latches, and ladders on Specification DOT 406, DOT 407 and DOT 412 cargo tank motor vehicles that transport petroleum crude oil under the Hazardous Materials Regulations (HMR;49 CFR Parts 171-180). Your questions are paraphrased and answered below:

QI. What DOT regulations apply to cargo tank hatch assemblies for DOT specification 406, 407, and 412 cargo tank motor vehicles?

AI. Section 178.345-5 of the HMR specifies the requirements for manhole assemblies on DOT 406, 407, and 412 cargo tank motor vehicles. The term "hatch assembly" and "manhole assembly" are synonymous for regulatory purposes. Generally, a manhole assembly must be structurally capable of withstanding without leakage a static internal fluid pressure of at least 36 psig or cargo tank test pressure, whichever is greater.

Q2. Are there any DOT regulations that pertain to ladders on cargo tank motor vehicles?

A2. Under the HMR, ladders attached to cargo tank motor vehicles are regulated as appurtenances. An appurtenance includes any attachment to a cargo tank that has no lading retention or containment function and provides no structural support to the cargo tank, as defined in § 178.320 of the HMR. Design, construction, and installation requirements for such appurtenances are provided in § 178.345¬3(f) for DOT 406, 407, and 412 cargo tank motor vehicles.

I hope this answers your inquiry.

Sincerely,

Susan Gorsky

Senior Transportation Regulations Specialist

Office of Hazardous Materials Standards

178.345-5

Regulation Sections