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Interpretation Response #06-0138 ([Sharp Energy] [Mr. Larry R. Miller])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sharp Energy

Individual Name: Mr. Larry R. Miller

Location State: MD Country: US

View the Interpretation Document

Response text:

Jul 14, 2006

 

Mr. Larry R. Miller                 Reference No. 06-0138
Training and Regulatory Compliance Manager
Sharp Energy
520 Commerce Street
Salisbury, MD 21804

Dear Mr. Miller:

This is in response to your June 9, 2006 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180) applicable to a cargo tank requiring a leakage test. In your letter, you state that the date of test on the delivery hose assembly that is permanently attached to the hose reel mounted on the rear deck of a propane “bobtail” tanker truck is not always readily available to a Registered Inspector. Specifically, you ask whether the hose identification number and the condition of the delivery hose assembly and piping system must be noted by the Registered Inspector even if the test date is unavailable.

The answer is yes. As required under § 180.407, a Registered Inspector conducting a leakage test on a cargo tank requiring a leakage test must note the hose identification number, the date of test, and the condition of the hose assembly and piping system tested.

In addition, under § 180.416 of the HMR, after July 1, 2000, the date of test on the delivery hose assembly should always be readily available to a Registered Inspector. Section 180416(d)(5) states that, after July 1, 2000, the operator must complete a record documenting the test and inspection, including the date; the signature of the inspector; the hose owner; the hose identification number; the date of original delivery hose assembly and test; notes of any defects observed and repairs made; and an indication that the deliver hose assembly passed or failed the tests and inspections. A copy of each test and inspection record must be retained by the operator at its principal place of business or where the vehicle is housed or maintained until the next test of the same type is successfully completed.

I trust this satisfies your inquiry.

Sincerely,

 

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

180.407, 180.416 (d)(5)

Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks
180.416 Discharge system inspection and maintenance program for cargo tanks transporting liquefied compressed gases