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Interpretation Response #04-0005 ([Arbonite] [Mr. Lee K. Robinson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Arbonite

Individual Name: Mr. Lee K. Robinson

Location State: PA Country: US

View the Interpretation Document

Response text:

May 11, 2004

 

Mr. Lee K. Robinson                Reference No. 04-0005
Arbonite
3826 Old Easton Road
Doylestown, PA 18901

Dear Mr. Robinson:

This responds to your December 22, 2003, letter requesting clarification on inspection of non-DOT specification 407 and 412 cargo tanks constructed from glass fiber reinforced plastics (GFRP) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether these cargo tanks are subject to the “L” lining inspection under § 180.407(f) and the internal visual inspectiont “I” under § 180.407(c).

Cargo tanks constructed from GFRP are authorized only by DOT exemption.  These DOT exemptions, e.g., DOT E-11903 and DOT E-12516 enclosed, specifically waive Special Provisions B15 and B23 in the HMR.  These cargo tanks do not have a lining and, therefore, are not subject to the lining inspection requirements of § 180.407(f). However, these cargo tanks are subject to the internal visual inspection requirements of § 180.407(e).

I hope this answers your inquiry.

Sincerely,

 

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

Enclosures

180.407

Regulation Sections

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