Interpretation Response #14-0117 ([Arkema, Inc.] [Ms. Christina Kurtz])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Arkema, Inc.
Individual Name: Ms. Christina Kurtz
Location State: PA Country: US
View the Interpretation Document
Response text:
March 23, 2015
Ms. Christina Kurtz
Manager, Regulations and Packaging
Health, Environment and Safety
Arkema, Inc.
900 First Avenue, Building #2
King of Prussia, PA 19406-1308
Ref. No. 14-0117
Dear Ms. Kurtz:
This responds to your June 10, 2014 request for clarification of the rear-end protection requirements for cargo tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification of rear-end tank protection requirements based on the design requirements of § 178.345-8(d)(1).
The rear-end cargo tank protection device must be designed so that it can deflect at least 6 inches horizontally forward with no contact between any part of the cargo tank motor vehicle which contains lading during transit and with any part of the rear-end protection device, or with a vertical plane passing through the outboard surface of the protection device. If the piping is not in the horizontal plane of the bumper, then the 6 inch standard must be measured to a vertical plane passing through the outboard surface of the device. Furthermore, we expressed concern regarding the drain lines from the piping in that they are clearly in the horizontal plane of the bumper. Please be aware that drain lines from piping must also be in compliance with § 178.345-8(d)(1).
I hope this answers your inquiry. If you need additional assistance, please contact this Office at (202) 366-8553.
Sincerely,
Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
178.345-8(d)(1)
Regulation Sections
| Section | Subject |
|---|---|
| 178.345-8 | Accident damage protection |