Interpretation Response #21-0007
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 13, 2021
John Freiler
Engineering Manager
Truck Trailer Manufacturers Association
7001 Heritage Village Plaza
Suite 220
Gainesville, VA 20155
Reference No. 21-0007
Dear Mr. Freiler:
This letter is in response to your January 27, 2021, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements for installing lightweight attachments to a cargo tank motor vehicle. Specifically, you ask about the requirements in § 178.345-3(f)(2) and whether the term "lightweight attachment" is limited exclusively to a conduit clip, brake line clip, skirting structure, lamp mounting bracket, or placard holder.
The answer is no. In accordance with § 178.345-3(f)(2), a "lightweight attachment" to a cargo tank wall such as a conduit clip, brake line clip, skirting structure, lamp mounting bracket, or placard holder must be of a construction having lesser strength than the cargo tank wall materials and may not be more than 72 percent of the thickness of the material to which it is attached. The words “such as” used in § 178.345-3(f)(2) denotes that a conduit clip, brake line clip, skirting structure, lamp mounting bracket, and placard holder are all examples of a lightweight attachment. The examples are not an exhaustive list; however, these types of items are constructed to have lesser strength than the cargo tank wall materials and be not more than 72 percent of the thickness of the material to which it is attached.
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
178.345-3(f)(2)
Regulation Sections
| Section | Subject |
|---|---|
| 178.345-3 | Structural integrity |