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Interpretation Response #11-0251 ([Allmetal Inc.] [Mr. Gene Guichu])

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

Interpretation Response Details

Response Publish Date:

Company Name: Allmetal Inc.

Individual Name: Mr. Gene Guichu

Location State: NV Country: US

View the Interpretation Document

Response text:

December 19, 2011



Mr. Gene Guichu
Plant Manager
Allmetal Inc.
1301 E. Glendale Ave
Sparks, NV 89431

Ref. No. 11-0251

Dear Mr. Guichu:

This responds to your October 11, 2011 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to qualification and maintenance requirements for DOT 107A seamless steel tank car tanks. In your letter, you state that the DOT 107A tank is used to store Helium for manufacturing operations and never offered for transportation. Specifically, you ask PHMSA to clarify the applicability of the test and inspection requirements specified in § 180.519.

Qualification and maintenance requirements for tank cars are specified in Part 180, Subpart F. In accordance with § 180.507, each tank car marked as meeting a "DOT" specification must be compliant with the relevant sections of the HMR applicable to that specification, including qualification and maintenance requirements of Part 180. Section 180.519 sets forth requirements for periodic retest and inspection of tank cars. The tests and inspections described in § 180.519 for DOT 107A tanks must be performed in accordance with the requirements and intervals specified in that section.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.


Ben Supko
Acting Chief, Standards Development
Standards and Rulemaking Division


Regulation Sections

Section Subject
180.519 Periodic retest and inspection of tank cars other than single-unit tank car tanks