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Interpretation Response #13-0143

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

Interpretation Response Details

Response Publish Date: 11-13-2013
Individual Name: Mr. Joe Calonge
Location state: GA    Country: US

View the Interpretation Document

Response text:

November 13, 2103

Mr. Joe Calonge
1365 Grove Park Lane
Cumming, GA   30041-8098

Ref. No. 13-0143

Dear Mr. Calonge:

This responds to your July 17, 2013 request for clarification of the requirements for the repair, modification, stretching, rebarrelling or mounting of specification cargo tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask for clarification of the term “work” as it is used in § 180.413(d)(2).

Your questions are paraphrased and answered as follows:

Q1. How does PHMSA define the term “work” as used in § 180.413(d)(2)?

A1. The HMR does not define the term “work.”  As used in § 180.413(d)(2), the term “work” refers to functions performed to modify, stretch, or rebarrel a cargo tank motor vehicle.

Q2. If a part of a cargo tank motor vehicle is modified in accordance with § 180.413(d)(2), does the entire cargo tank motor vehicle have to comply with the applicable specification?

A2. Yes.  The cargo tank motor vehicle must comply with the applicable specification.  Pursuant to § 180.413(d)(2), all new material and equipment affected by modification, stretching, or rebarrelling must meet the requirements of the specification in effect at the time such modification, stretching, or rebarrelling is performed, and the structural integrity requirements described in §§ 178.337-3, 178.338-3, and 178.345-3.

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


Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
§ 180.413 Repair, modification, stretching, rebarrelling, or mounting of specification cargo tanks