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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

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
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.



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



Regulation Sections

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