Interpretation Response #12-0005 ([Global Passive Safety System Ltd.] [Mr. Andy Abrams])

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

Interpretation Response Details

Response Publish Date: 05/01/2012

Company Name: Global Passive Safety System Ltd.

Individual Name: Mr. Andy Abrams

Location State: PA Country: US

View the Interpretation Document

Response text:

May 1, 2012

Mr. Andy Abrams
Global Passive Safety System Ltd.
761 West Sproul Road, Suite 208
Springfield, PA 19064

Ref. No.: 12-0005

Dear Mr. Abrams:

This responds to your January 4, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hose assemblies. Specifically, you inquire whether a metallic hose assembly made with a corrugated tube of 316SS and an outer braid of 304SS with a working pressure of 400+ p.s.i. and a burst of 2000 can be used in liquefied petroleum gas (LPG) and anhydrous ammonia (NH3) cargo tanker service.

In accordance with § 173.315(n)(2), for a cargo tank motor vehicle in other than metered delivery service, there are no specific HMR provisions dictating the material from which a delivery hose must be comprised. However, Pipeline and Hazardous Materials Safety Administration (PHMSA) does specify in § 178.337-9 the requirements (burst pressures, weights, damage protection, free from leaks, etc.) for piping, valves, hoses, and fittings on MC 331 cargo tanks intended to contain compressed gases. Further, the hose identification, inspection, and testing requirements for a delivery hose assembly on a cargo tank used to transport liquefied compressed gases are specified in § 180.416 of the HMR, including the rejection criteria in paragraph (g). Additionally, it is the responsibility of the person offering a hazardous material for transportation to ensure that the packagings and its appurtenances (piping, valves, hoses, fittings, etc.) are compatible with its lading.

Please be aware that these hoses may be subject to the Occupation Safety and Health Administration (OSHA) Standards in 29 CFR, and specific questions about requirements for equipment such as a hose should be directed to OSHA and any applicable state regulatory authorities. However, a review of 29 CFR § 1910.111(b)(8) states that hoses used in ammonia service shall conform to the joint Agricultural Ammonia Institute - Rubber Manufacturers Association (RMA) Specifications for Anhydrous Ammonia Hose. Subsequently, a cursory

analysis of the documents published by RMA make no mention of a metallic hose assembly as is described above. For further assistance, you may contact Jeffrey J. Wanko, Safety Engineer for OSHA Directorate of Enforcement Programs, by phone at (202) 746-2667 or email at JWanko@dol.gov.

I hope 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
173.315

Regulation Sections