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Interpretation Response #12-0105 ([Arcet Cylinder Services Div.] [Mr. David Goff])

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

Interpretation Response Details

Response Publish Date:

Company Name: Arcet Cylinder Services Div.

Individual Name: Mr. David Goff

Location State: VA Country: US

View the Interpretation Document

Response text:

October 1, 2012



Mr. David Goff
Facility Manager
Arcet Cylinder Services Div.
10095 Whitesel Rd.
Ashland, VA 23005

Reference No. 12-0105

Dear Mr. Goff:

This is in response to your email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to external visual inspections on certain MC 338 cargo tank motor vehicles. In your letter, you state that the cargo tank motor vehicles have a device that maintains the pressure at 17 psi. You ask whether an external visual inspection on an MC 338 cargo tank motor vehicle that transports liquid argon and liquid nitrogen at low pressure not to exceed 25.3 psi is required by §§ 173.33 and 180.407, or whether the inspection is excepted by § 173.320(a).

Section 173.320(a) excepts motor vehicles and rail cars from the requirements of the subchapter when the vehicle is carrying atmospheric gases and helium, cryogenic liquid; is insulated; and designed and constructed so that the pressure in such packaging will not exceed 25.3 psig under ambient temperature conditions during transportation, except as specified in § 173.320(a)(1), (a)(2) and (a)(3). Provided that the cargo tank motor vehicle meets these specified requirements, it is excepted from all other requirements in the HMR, including an external visual inspection. The cargo tank as described in your letter appears to qualify for this exception. However, it should be noted that in order to display MC 338 markings, a cargo tank must meet the continuing qualification, maintenance, and periodic testing requirements for a MC 338 cargo tank as specified in § 180.407.

I hope this information is helpful. Please contact this office should you have additional questions.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.320, 180.407

Regulation Sections

Section Subject
173.320 Cryogenic liquids; exceptions
180.407 Requirements for test and inspection of specification cargo tanks