Interpretation Response #10-0137 ([National Oilwell Varco] [Mr. Jianke Wang, PH D, PE])
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 Oilwell Varco
Individual Name: Mr. Jianke Wang, PH D, PE
Location State: TX Country: US
View the Interpretation Document
Response text:
August 26, 2010
Mr. Jianke Wang, PH D, PE
Senior Project Engineer
National Oilwell Varco
2800 N. Frazier Street
Conroe, TX 77303
Ref. No. 10-0137
Dear Mr. Wang:
This responds to your July 1, 2010 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether an intermediate bulk container (IBC) is authorized for repeated offshore use "IN OPEN SEAS".
According to your letter, you have IBCs and UN/DOT Portable tanks that require certification for offshore transportation in open seas (dynamic lifting for offshore oil exploration). You state that the transporting liquid is diesel. You further state that your IBCs are UN tanks, but, they are not UN Portable tanks which are also designed and constructed in accordance with the International Maritime Dangerous Goods (IMDG) Code's "Guidelines for the Approval of Containers Handled in Open Seas" (MSC/Circ.860).
The design, testing, and use of offshore containers are not addressed in the HMR. IBCs, portable tanks, or other container types designed for multi-modal transportation of hazardous materials in accordance with the IMDG Code or the HMR are generally not considered suitable as offshore containers unless they are also specially designed to withstand dynamic lifting and impact forces likely to be encountered during open sea operations. If your IBCs meet the additional requirements as contained in MSC/Circ.860, then they may also be suitable for open sea operations. If you have any additional questions regarding offshore containers or offshore operations, please contact the U.S. Coast Guard, Office of Operating and Environmental Standards (CG-522), 2100 2nd Street, SW, Washington, DC 20593-7126, Ph: (202) 372-1401, Fax: (202) 372-1926.
I hope this answers your inquiry. If you need further assistance, please contact this office.
Sincerely,
Ben Supko
Acting Chief, Standards Development
Office of Hazardous Materials Standards
178.274
Regulation Sections
| Section | Subject |
|---|---|
| 178.274 | Specifications for UN portable tanks |