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Interpretation Response #11-0157 ([Mr. Daniel G. Shelton] [HazMat Resources, Inc.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mr. Daniel G. Shelton

Individual Name: HazMat Resources, Inc.

Location State: TX Country: US

View the Interpretation Document

Response text:

May 31, 2012









Mr. Daniel G. Shelton


HazMat Resources, Inc.

124 Rainbow Drive

Suite 2471

Livingston, TX 77399-1024


Ref. No. 11-0157


Dear Mr. Shelton:


This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180) applicable to its discharge system inspection and maintenance program for specification MC 331 cargo tanks in liquefied compressed gas service.  I have paraphrased your questions and answered them as follows:


Q1.      The term "delivery hose assembly" is defined in § 180.403.  The term "hose assembly" is not.  Both terms appear to be used interchangeably in Parts 178 and 180 of the HMR.  Do they have the same meaning?


A1.      No, they do not.


Q2.      Section 178.337-9(b)(7) requires a hose assembler to permanently mark a hose assembly with a unique identification number in addition to the month and year of its original (i.e., new) pressure test conducted in accordance with § 180.416(f).  Section 180.416(f) appears to require that only the month and year of the pressure test be permanently marked on the hose assembly.  Which marking requirement is correct?


A2.      Because Part 178 is generally reserved for new construction, and Part 180 for continuing qualification, the marking requirement prescribed in § 180.416 assumes the hose assembly has been ("originally") permanently marked with a unique identification number.  See the recordkeeping requirements in § 180.416(f)(3).


Q3.      Section 178.337-9(b)(7) states that a hose assembler must:

  • Permanently mark each hose assembly with a unique identification number.
  • Demonstrate that each hose assembly is free from leaks by performing the tests and inspections in §180.416(f) of the HMR.
  • Mark each hose assembly with the month and year of its original pressure test.

Which date is required to be marked for the leakage test prescribed in § 178.337-9(b)(7), the assembly test date or the actual test date of the complete delivery hose assembly?

A3.      The original pressure test date required by § 178.337-9(b)(7) is the assembly leakage test date performed in accordance with the tests and inspections prescribed in                   § 180.416(f).

Q4.      Is there a marking requirement when a leakage test is conducted under                        § 180.407(h)(4) on a delivery hose assembly?


A4.      No, there is not.


Q5.      A delivery hose assembly, as defined in § 180.403, means a liquid delivery hose and its attached couplings.  Emphasis added.  Assume a hose assembly is purchased from a hose assembler.  The couplings are then attached to the hose assembly resulting in a delivery hose assembly as defined by the HMR.  Is a leakage test now required to be conducted as prescribed in § 180.416(f)?  


A5.      The answer is yes, because couplings were never attached to the hose assembly when pressure tested by the hose assembler.


Q6.      What markings must be placed on the successfully-tested, completed delivery hose assembly?


A6.      As prescribed in § 180.416(f)(2), the delivery hose assembly must be permanently marked with the month and year of the test.


Q7.      What are the test facility recordkeeping requirements for a successfully-tested, completed delivery hose assembly?


A7.      For the testing facility, none are prescribed.  However, as prescribed in                      § 180.416(f)(3), the cargo tank 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 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.


Q8.      If a hose assembler successfully tests and fully marks a complete delivery hose assembly as prescribed in §§ 178.337-9(b)(7) and 180.416(f), is the operator required to retain documents for such tests?


A8.      The answer is no, provided new test documents are prepared, as appropriate, and the required markings are placed on the delivery hose assembly.


I trust this satisfies your inquiry.  Please contact us if we can be of any further assistance.







T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division


180.416, 178.337-9, 180.403

Regulation Sections

Section Subject
178.337-9 Pressure relief devices, piping, valves, hoses, and fittings
180.416 Discharge system inspection and maintenance program for cargo tanks transporting liquefied compressed gases