Interpretation Response #17-0048 ([Jackson Energy/ Capitol Distributing] [Mr. Rob Berrier])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Jackson Energy/ Capitol Distributing
Individual Name: Mr. Rob Berrier
Location State: ID Country: US
View the Interpretation Document
Response text:
August 14, 2017
Rob Berrier
Fleet Safety Manager
Jackson Energy/Capitol Distributing
3450 E. Commercial Court
Meridian, ID 83642
Reference No. 17-0048
Dear Mr. Berrier:
This letter is in response to your May 8, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the specification nameplate requirements for a Department of Transportation (DOT) 400-series cargo tank. Specifically, you provide a picture of a DOT-406 specification nameplate with a test pressure marking of "TEST PRESSURE: 5" and ask if it meets the requirements of § 178.345 14(b)(4) even though the unit of measure (i.e., psig) is not included on the nameplate.
The answer is yes. In accordance with § 178.345-14(b)(4), the corrosion resistant nameplate is required to display the "cargo tank test pressure (Test P), in psig." Because the unit of measure is specified in the HMR, it is understood that the test pressure marking on the nameplate is in psig. However, to avoid further frustration of shipments in the future, it is suggested that the unit of measure be included on the nameplate for all applicable information, but it is not required.
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
178.345-14(b)(4)