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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #15-0226 ([Tri Tank Corporation] [Mr. Jim Lawson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Tri Tank Corporation

Individual Name: Mr. Jim Lawson

Location State: NY Country: US

View the Interpretation Document

Response text:

April 14, 2016

Jim Lawson
Tri Tank Corporation
115 Farrell Road
Syracuse, NY 13209

Ref. No. 15-0226

Dear Mr. Lawson:

This responds to your email of November 18, 2015 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the external visual inspection of cargo tanks.  In your request, you ask whether paint used to cover the exterior of a cargo tank could be considered a “coating.”

For purposes of § 180.407, paint may preclude an external visual inspection.  Specifically,
§ 180.407(d)(1) states, “[i]f 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, one must consider whether the application of paint on the exterior of a cargo tank wall prevents the performance of an external visual inspection that conforms to the requirements of the HMR (e.g., §§ 180.407(d)(2) through (d)(7)).  

It is the opinion of this Office that the Registered Inspector (as defined in § 171.8), or other appropriate person meeting the requirements of § 180.409, would determine whether the paint has covered certain areas of the cargo tank wall in such a way that prevents a proper external visual inspection from being performed.  If the Registered Inspector determines that the application of paint does indeed prevent a proper external visual inspection, an internal visual inspection of those areas affected by the paint would be required in conjunction with the external visual inspection for the remaining areas of the cargo tank wall.

I hope this answers your inquiry.  If you need additional assistance, please contact this Office again.   

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

180.407, 180.407(d)(1), 180.407(d)(2) through (d)(7),  171.8, 180.409

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
180.407 Requirements for test and inspection of specification cargo tanks