USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

Interpretation Response #06-0034 ([National Tank Truck Carriers, Inc.] [Mr. Thomas P. Lynch])

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

Interpretation Response Details

Response Publish Date:

Company Name: National Tank Truck Carriers, Inc.

Individual Name: Mr. Thomas P. Lynch

Location State: VA Country: US

View the Interpretation Document

Response text:

Jul 31, 2006

Mr. Thomas P. Lynch               Reference No. 06-0034
Vice President and General Counsel
National Tank Truck Carriers, Inc.
2200 Mill Rd.
Alexandria, VA 22314

Dear Mr. Lynch:

This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180) regarding the applicability of an exception allowing cargo tank motor vehicles to undergo a partial external visual inspection and a leakage test to fulfill annual test and inspection requirements. You ask whether the exception applies to all materials being transported in insulated MC 330 and MC 331 cal-go tank motor vehicles and, in particular, to the transportation of pyrophoric materials.

The answer is yes. The table in § 180.407(c) excepts insulated MC 330 and MC 331 cargo tank motor vehicles from the internal visual inspection requirement and this exception applies to all hazardous materials being transported in insulated MC 330 and MC 331 cargo tank motor vehicles. These cargo tank motor vehicles are required to have an internal visual inspection at least once every five years in conjunction with the pressure test. Because the insulation prevents a complete external visual inspection, those items able to be externally inspected must be inspected annually in accordance with § 180.407(d) and noted in the inspection report. The annual, partial external visual inspection and a leakage test performed in accordance with § 180.407(h) fulfill :he annual inspection and test requirements applicable to insulated MC 330 and MC 331 cargo tank motor vehicles. Once the external visual inspection and leakage test have been successfully completed, the tank may be marked in accordance with § 180.415(b)).

I hope this information is helpful. Please contact this office should you have additional questions.

Sincerely,

 

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

180.407(c)

Regulation Sections

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