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Interpretation Response #10-0189 ([Oak Point Service] [Mr. Jim Poulsen])

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

Interpretation Response Details

Response Publish Date:

Company Name: Oak Point Service

Individual Name: Mr. Jim Poulsen

Country: CA

View the Interpretation Document

Response text:

October 28, 2011



Mr. Jim Poulsen


Oak Point Service

272 Oak Point Hwy

Winnipeg, MB R2R 1V1

Ref. No.: 10-0189

Dear Mr. Poulsen:

This responds to your letter regarding the requirements under the Hazardous Materials

Regulations (HMR; 49 CFR 171-180) applicable to cargo tank motor vehicle (CTMV) linings,

emergency discharge control equipment and a "dated signature" required on an inspection

report. Your questions are paraphrased and answered as follows:

Q1. Do the requirements regarding CTMV linings and coatings specify that any "coating" which is 15 mils or more is considered a lining, and which must be inspected using a "spark tester?"

A1. The answer is no. In accordance with the HMR, cargo tank motor vehicle linings must be inspected as specified in § 180.407(f). The integrity of the lining on all lined cargo tanks, when lining is required, must be verified at least once each year. Rubber (elastomeric material) linings must be tested for holes. The equipment used to test rubber linings must consist of a high frequency "spark tester" capable of producing sufficient voltage to ensure proper calibration. Linings made of other than rubber must be tested using equipment and procedures prescribed by the lining manufacturer or lining installer (See

§ 180.407(f)(1) and (f)(2)).

Q2. In a C or A train configuration, is the passive shutdown system (more specifically the Smart Hose) as described in § 173.315(n)(2) required to be carried on each lead trailer and the pup trailer even though only "one" trailer is unloaded at any one time or will one smart hose suffice?

A2. The answer is yes. In a C or A train configuration (i.e., a truck tractor pulling more than one trailer connected by "A" or "C" dolly), each cargo tank motor vehicle (CTMV) in liquefied compressed gas service is required to have an emergency discharge control capability. A CTMV in other than metered delivery service must have a means to automatically shut off the flow of product without the need for human intervention within 20 seconds of an unintentional release caused by a complete separation of liquid delivery hose (passive shut down capability).

If a CTMV operating in both metered and non-metered delivery service is equipped with a passive means of shut down that meets the requirements in § 173.315(n)(2) and functions for both types of deliveries, then it need not also be equipped with an off-truck remote means of shut down. However, if the passive means of shutdown only function for non-metered deliveries, then the CTMV must also be equipped with an off-truck remote shutdown system.

Q3. In § 180.417 (b)(2)(x), it states that each inspection report must have "dated signature" of the registered inspector and the cargo tank owner. Can a representative (employee) of the cargo tank owner date and sign the inspection reports?

A3. The answer is yes. A test and inspection report must include the information specified in § 180.417(b) and/or (c), as appropriate, including the location of defects found; method of repair; and dated signatures of both the Registered Inspector and the cargo tank owner. An owner means the person who owns a cargo tank motor vehicle used for the transportation of hazardous materials, or that person"s authorized agent (See §180.403). A representative (employee/authorized agent) of the cargo tank owner may date and sign the inspection reports on behalf of the cargo tank owner.

Thank you for the information that CGA Technical Bulletin TB-2 (Guidelines for Inspection and

Repair of MC-330 and MC-331 Cargo Tanks) referenced in §§ 180.407 and 180.413 is being

Replaced by CGA P-26.

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



Ben Supko

Acting Chief, Standards Development

Standards and rulemaking Division

173.315, 180.407, 180.417

Regulation Sections

Section Subject
173.315 Compressed gases in cargo tanks and portable tanks
180.407 Requirements for test and inspection of specification cargo tanks
180.417 Reporting and record retention requirements