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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 #08-0097 ([C&R Fleet Services, Inc.] [Mr. Anthony Reid])

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

Interpretation Response Details

Response Publish Date:

Company Name: C&R Fleet Services, Inc.

Individual Name: Mr. Anthony Reid

Location State: GA Country: US

View the Interpretation Document

Response text:

December 30, 2008

Mr. Anthony Reid

C&R Fleet Services, Inc.

353 O"Dell Road

Griffin, Georgia 30224

Ref. No.: 08-0097

Dear Mr. Reid:

This responds to your letter regarding whether Registered Inspectors performing requalification inspections in accordance with the Hazardous Materials Regulations (HMR), §180.407, specifically VKIP tests on a cargo tank motor vehicle, must also comply with Federal Motor Carrier Safety Administration Regulations (FMCSR), § 396.21, Subchapter B, Appendix G, known as "Annual" inspection. This inspection covers components such as brake system, coupling devices, exhaust system, fuel system, lighting devices, safe loading, steering mechanism, suspension, frame, tires, wheels and rims, windshield glazing, and windshield wipers.

The HMR do not require DOT Registered Inspectors to perform compliance reviews subject to Part 396 of the FMCSR. Also, a person who performs only the inspections specified in Part 396 of the FMCSR is not required to be a DOT Registered Inspector. As a matter of courtesy, if a Registered Inspector observes deficiencies in the components covered by the FMCSR inspection, the inspector should bring it to the motor carrier"s or owner"s attention.

I hope this information is helpful. If we can be of further assistance, please contact us.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

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