Interpretation Response #18-0125
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Truck Trailer Manufacturers Association
Individual Name: John Freiler
Location State: VA Country: US
View the Interpretation Document
Response text:
April 16, 2019
John Freiler
Truck Trailer Manufacturers Association
7001 Heritage Village Plaza, Suite 220
Gainesville, VA 20155
Reference No. 18-0125
Dear Mr. Freiler:
This letter is in response to your October 5, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the design of MC-331 cargo tanks. Specifically, you ask about the requirements for shear sections on valves.
We have paraphrased and answered your questions as follows:
Q1. You ask if § 178.337-10(f) applies to valves located within a recessed well that meet the accident damage protection requirements on top of an MC-331 cargo tank.
A1. The answer is yes. Section 178.337-10(f) still applies to valves located on the top of an MC‑331 cargo tank that meet the requirements for accident damage protection.
Q2. You ask if a ball valve without a shear section may be used for liquid and vapor connections within a recessed well on top of an MC-331 cargo tank.
A2. The answer is no. A shear section is still required. The ball valve and recessed well do not except the cargo tank from the requirements for shear sections on valves.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division
Regulation Sections
| Section | Subject |
|---|---|
| 178.337-10 | Accident damage protection |