Interpretation Response #16-0151 ([HazMat Resources, Inc.] [Mr. Daniel Shelton])

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

Interpretation Response Details

Response Publish Date: 03/03/2017

Company Name: HazMat Resources, Inc.

Individual Name: Mr. Daniel Shelton

Location State: TN Country: US

View the Interpretation Document

Response text:

March 3, 2017

Daniel Shelton
President
HazMat Resources, Inc.
141 Wendover Drive
Kingsport, TN 37663

Reference No. 16-0151

Dear Mr. Shelton:

This letter is in response to your September 13, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the permanent installation of delivery hose assemblies on MC331 cargo tanks. You describe a scenario in which the delivery hose assembly is attached to a fitting coming from the unloading outlet while in transportation. You provide in your letter several photographs of delivery hose configurations and ask whether any of the configurations constitute non-compliance with the HMR—and specifically, which requirement.

Based solely on the photographs provided, this Office cannot determine whether each configuration would comply with the HMR, except for the scenario in which the ACME fitting is clearly outside of the protective and, therefore, non-compliant. Section 178.337-10(a) states that all valves, fittings, pressure relief devices, and other accessories to the tank proper shall be protected in accordance with paragraph (b) of this section against such damage as could be caused by collision with other vehicles or objects, jack-knifing, and overturning. All fittings, including the ACME fitting, and couplings of a delivery hose assembly, but not the hose itself, on an MC331 cargo tank would be considered a fitting or other accessory to the tank. Therefore, in accordance with § 178.337-10(b), for a delivery hose assembly to remain connected to an MC331 cargo tank while in transportation, all of the fittings and couplings (1) must have a protective device or housing designed to withstand static loading in any direction equal to twice the weight of the tank and attachments when filled with the lading, using a safety factor of not less than four, based on the ultimate strength of the material to be used, without damage to the fittings protected, and (2) must be made of metal at least 3/16-inch thick.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

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

178.337-10(a), 178.337-10(b)

Regulation Sections