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Interpretation Response #05-0120

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

Interpretation Response Details

Response Publish Date: 03-31-2006
Company Name: Cayias Consulting    Individual Name: Mr. John Cayias
Location state: TX    Country: US

View the Interpretation Document

Response text:

Mar 31, 2006


Mr. John Cayias                      Reference No. 05-0120
Cayias Consulting
15 Vista Cliff Place
Richardson, TX 75080

Dear Mr. Cay: as:

This responds to your request for clarification of the periodic inspection and test requirements for non-DOT specification cargo tanks authorized under the Hazardous Materials Regulations HMR; 49 CFR Parts 171-180). Specifically, you ask about inspection and retest requirements for non-DOT specification cargo tanks authorized to transport elevated temperature materials.

A non-DOT specification cargo tank used for the transportation of elevated temperature materials, such as molten sulfur, must meet the general requirements in § 173.247(g) of the HMR. A non- DOT specification cargo tank is not subject to the periodic inspection or retest requirements of the HMR. It is the shipper"s responsibility to assure that the cargo tank conforms to all applicable HMR requirements. Note that in accordance with § 173.24(e), the shipper must ensure that a packaging is compatible with its lading even if that packaging is authorized for transportation of the material in Part 173 of the HMR. In the particular case of molten sulfur, the variability of its composition and other factors related to the operational service of the cargo tank may require that a shipper institute certain inspections and frequencies beyond that required of a comparable DOT specification tank.

I hope this information is helpful. Please contact us if you require additional assistance



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

173.247(g), 173.24(e)

Regulation Sections

Section Subject
§ 173.24 General requirements for packagings and packages