Interpretation Response #20-0094
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Stabilis Solutions
Individual Name: Mr. Vignesh Pandurengan
Location State: TX Country: US
View the Interpretation Document
Response text:
May 28, 2021
Mr. Vignesh Pandurengan
Maintenance Specialist
Stabilis Solutions
10375 Richmond Avenue, Suite 700
Houston, TX 77042
Reference No. 20-0094
Dear Mr. Pandurengan:
This is in response to your December 7, 2020, email and subsequent conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a Department of Transportation (DOT) cargo tank motor vehicle (CTMV). Specifically, you ask whether an insulated MC 338 CTMV transporting non-corrosive materials and equipped with manholes must undergo an internal visual inspection within certain time intervals.
The answer is no. Section 180.407(c) excepts DOT Specification MC 338 cargo tanks from the internal visual inspection requirement when transporting non-corrosive materials. However, MC 338 cargo tanks are required to be externally inspected annually. If the insulation of the MC 338 CTMV cargo tank you describe is found to preclude a complete external inspection, the cargo tank would be required to be internally inspected in order to complete the external inspection requirements found in §§ 180.407(c) and 180.407(d). In addition, because the cargo tank you describe is equipped with manholes, Note 4 of § 180.407(c) would apply, and a hydrostatic or pneumatic pressure test may be performed in place of the internal inspection.
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 Branch
Standards and Rulemaking Division
180.407(c), 180.407(d)