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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 #17-0058

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 Environmental Group

Individual Name: Mr. Vince Phillips

Location State: NY Country: US

View the Interpretation Document

Response text:

September 29, 2017
Vince Phillips
Maintenance Supervisor
Hazmat Environmental Group
60 Commerce Drive
Buffalo, NY  14218-1040
Reference No. 17-0058
Dear Mr. Phillips:
This letter is in response to your June 1, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to inspection requirements for the areas on a cargo tank covered by the upper coupler (fifth wheel).  You describe a lined cargo tank transporting lading that is corrosive to the tank but—due to the lining—does not come in direct contact with the tank itself.  You ask whether the areas covered by the upper coupler (fifth wheel) must be tested every two years in accordance with § 180.407(d)(2)(ix), even though the tank is lined.
The answer is yes.  Section 180.407(d)(2)(ix) requires that when transporting lading corrosive to the tank, areas on a cargo tank covered by the upper coupler (fifth wheel) must be inspected once every two years for corroded and abraded areas, dents, distortions, defects in welds, and any other condition that might render the tank unsafe for transportation service.  The lading you describe is corrosive.  Therefore, even though the lading does not physically come in contact with the tank, the HMR require that the inspection be completed every two years.
I hope this information is helpful.  Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development
Standards and Rulemaking Division

Regulation Sections

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