Interpretation Response #22-0005
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Desert Isle Inc., Lahaina Air Conditioning, Ltd.
Individual Name: Peter Faulkner
Location State: HI Country: US
View the Interpretation Document
Response text:
June 23, 2022
Mr. Peter Faulkner
President
Desert Isle Inc., Lahaina Air Conditioning, Ltd.
P.O. Box 700699
Kapolei, HI 96709-0699
Reference No. 22-0005
Dear Mr. Faulkner:
This letter is in response to your January 20, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the periodic testing, inspection, and repair of portable tanks. Specifically, you ask whether T75 United Nations (UN) portable tanks used for the transportation of refrigerated, liquefied gases (e.g., carbon dioxide) are excepted from the pneumatic test required by the 5-year periodic inspection and test specified in § 180.605(e).
The answer is yes. As specified in § 180.605(e), portable tanks used for the transportation of refrigerated, liquefied gases are excepted from the requirement for internal inspection and the hydraulic pressure test (hydrostatic or pneumatic) during the 5-year periodic inspection and test, if the portable tanks were pressure tested to a minimum test pressure of 1.3 times the design pressure using an inert gas, as prescribed in § 178.338-16(a) and (b), before putting the portable tank into service initially, and after any exceptional inspections and tests specified in § 180.605(f).
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
178.338-16(a), 178.338-16(b), 180.605(e), 180.605(f)