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Interpretation Response #14-0082 ([Renaldo Sales & Service, Inc.] [Mr. Kerry M. Fitzgeral])

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

Interpretation Response Details

Response Publish Date:

Company Name: Renaldo Sales & Service, Inc.

Individual Name: Mr. Kerry M. Fitzgeral

Location State: IL Country: US

View the Interpretation Document

Response text:

July 23, 2014

Mr. Kerry M. Fitzgerald
Compliance Manager
Renaldo Sales & Service, Inc.
1770 Mile Strip Road
North Collins, NY 14111                                                                                                                                                   
Ref. No. 14-0082

Dear Mr. Fitzgerald:

This responds to your letter dated April 10, 2014 requesting clarification of the minimum qualification requirements for cargo tank inspectors under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if an employee, who is trained to perform all aspects of an internal visual inspection, but is not a Registered Inspector, may perform the internal visual inspection of an MC331 cargo tank under the supervision of a Registered Inspector. 

The answer is no.  Section 180.409 sets forth the minimum qualifications for cargo tank inspectors and testers.  In accordance with § 180.409(d), external and internal visual inspections must be accomplished by a Registered Inspector.  Section 180.409(d) does authorize an employee of a motor carrier or a cargo tank owner who is not a Registered Inspector to perform the hydrostatic or pneumatic pressure test required by

§§ 180.407(g)(1)(viii) and 180.407(g)(1)(ix), provided that: (1) The employee is familiar with the cargo tank and is trained and experienced in the use of the inspection and testing equipment used; (2) The employer submits certification that such employee meets the qualification requirements to the Associate Administrator, Attn: (PHH-32), Pipeline and Hazardous Materials Safety Administration, Department of Transportation, East Building, 1200 New Jersey Avenue, SE., Washington, DC 20590; and (3) The employer retains a copy of the tester's qualifications with the documents required by §180.417(b).

I hope this information is helpful.  If you have further questions, please contact this office.


Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

180.409, 180.409(d), 180.407(g)(1)(viii), 180.407(g)(1)(ix), 180.417(b)

Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks
180.407 Requirements for test and inspection of specification cargo tanks
180.409 Minimum qualifications for inspectors and testers
180.409 Minimum qualifications for inspectors and testers
180.417 Reporting and record retention requirements