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Interpretation Response #14-0110 ([HazMat Resources, Inc.] [Mr. Danny Shelton])

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

Interpretation Response Details

Response Publish Date:

Company Name: HazMat Resources, Inc.

Individual Name: Mr. Danny Shelton

Location State: TX Country: US

View the Interpretation Document

Response text:

July 22, 2014

Mr. Danny Shelton
HazMat Resources, Inc.
124 Rainbow Drive, Suite 2471
Livingston, TX 77399-1024

Ref. No.: 14-0110

Dear Mr. Shelton,

This is in response to your email dated May 27, 2014, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the visual inspection of cargo tanks fitted with an external vinyl wrap.

In your letter you describe a scenario in which cargo tanks are wrapped in vinyl for advertising and or aesthetic purposes. It is your understanding that because the tank exterior is covered by the vinyl wrap, the tank cannot be completely inspected during an external visual inspection in accordance with § 180.407(d) and as such, would be subject to an annual internal visual inspection in accordance with § 180.407(e). Specifically, you ask if an external visual inspection may be performed on a vinyl wrapped cargo tank; or if a combination external and internal inspection may be performed to account for areas of the cargo tank that are covered by the vinyl wrap and not readily visible from the exterior.

Section 180.407(c) requires all specification cargo tanks to have an external visual inspection at least once each year. As provided in § 180.407(d)(1), if external visual inspection is precluded because any part of the cargo tank wall is externally lined, coated, or designed to prevent an external visual inspection, those areas of the cargo tank must be internally inspected. Therefore, in the scenario you describe where a vinyl wrap precludes an external inspection of certain areas of the cargo tank, the areas covered by vinyl wrap that prevent external inspection must be internally inspected in conjunction with the external visual inspection for the remaining areas of the cargo tank.

I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.


Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division

180.407(d), 180.407(e), 180.407(c), 180.407(d)(1)

Regulation Sections

Section Subject
180.407 Requirements for test and inspection of specification cargo tanks