Interpretation Response #11-0067 ([Airgas SAFECOR] [Mr. John Anderson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Airgas SAFECOR
Individual Name: Mr. John Anderson
Location State: WY Country: US
View the Interpretation Document
Response text:
May 17, 2011
Mr. John Anderson
Airgas SAFECOR
P.O. Box 20067
Cheyenne, WY 82003
Ref. No.: 11-0067
Dear Mr. Anderson:
This responds to your March 22, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the general requirements for specification MC 331 cargo tanks.
In your letter, you state that your company, Airgas SAFECOR (Airgas), carries permitted hazardous materials within specification MC 331 cargo tank motor vehicles. You state that some of your MC 331 cargo tanks are painted white with a light teal stripe across the horizontal axis of the tank. Additionally, you state that your other MC 331 cargo tanks are "wrapped" in a 3M ControltacTM Graphic Film with ComplyTM v3 Adhesive. The wrap is an ultraviolet (UV) reflective material that is designed to breathe and resist fading. You provide data of the temperature tests on the striped cargo tanks and product description data for the wrap. Specifically, you ask whether the light teal stripe and the wrap are permitted under § 178.337 of the HMR.
As specified in § 178.337-1(d), every uninsulated cargo tank permanently attached to a cargo tank motor vehicle shall, unless covered with a jacket made of aluminum, stainless steel, or other bright non-tarnishing metal, be painted a white, aluminum or similar reflecting color on the upper two-thirds of area of the cargo tank.
It is the opinion of this Office that both the light teal "striped" and the "wrapped" Airgas cargo tanks as shown in the photographs and data you supplied do not conflict with § 178.337-1(d); therefore, you appear to be in compliance with this section.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
178.337-1
Regulation Sections
| Section | Subject |
|---|---|
| 178.337-1 | General requirements |