Interpretation Response #03-0246 ([Degussa Corporation] [Mr. John Foglio])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Degussa Corporation
Individual Name: Mr. John Foglio
Location State: NJ Country: US
View the Interpretation Document
Response text:
May 20, 2004
Mr. John Foglio Reference No. 03-0246
Manager Hazardous Materials
Transportation Safety
Degussa Corporation
379 Interpace Parkway
P.O. Box 677
Parsippany, NJ 07054-0677
Dear Mr. Foglio:
This responds to your letter regarding the inspection of portable tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether it is permissible to use a video camera when performing an internal visual inspection under the periodic testing requirements of § 180.605. I apologize for the delay in responding.
The answer is yes. Section 180.605(g) specifies an internal visual inspection must ensure that the portable tank shell is inspected for pitting, corrosion, or abrasions, dents, distortions, defects in welds or any other conditions, including leakage, that might render the portable tank unsafe for transportation. In addition, the piping, valves, and gaskets must be inspected for corroded areas, defects, and other conditions, including leakage, that might render the portable tank unsafe for filling, discharge, or transportation. A video camera may be used to perform a visual internal inspection of a portable tank provided all of the internal areas can be viewed in a manner equivalent to that which would be expected if viewed directly by a person inside the tank.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
180.605