USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #22-0033

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: DOT Safety Solutions

Individual Name: Randy Decker

Location State: KS Country: US

View the Interpretation Document

Response text:

May 16, 2023

Randy Decker
DOT Safety Solutions
PO Box 25311
Overland Park, KS  66225

Reference No. 22-0033

Dear Mr. Decker:

This letter is in response to your April 19, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to qualification and maintenance of cargo tanks. Specifically, you describe a scenario where crude oil is transported in cargo tanks made of aluminum; you state that, as a registered inspector, you have firsthand experience that the crude oil transported in the region of service can be and is corrosive to an aluminum tank. You ask who is responsible for making the determination that the cargo tank was transporting a material that was corrosive to the cargo tank or valve.

In accordance with § 180.401, the requirements in Part 180, Subpart E for the qualification and maintenance of cargo tanks apply to any person responsible for the continuing qualification, maintenance, or periodic testing of a cargo tank. In § 180.403, corrosive to the tank or valve means that the lading has been shown through experience or test data to reduce the thickness of the material of construction of the tank wall or valve. Thus, if the crude oil in the region of service has been shown through experience or test data to reduce the thickness of the material of construction of the tank wall or valve, then the cargo tank must be subjected to the testing and inspection regimen for associated cargo tanks transporting lading corrosive to the tank found in § 180.407(c).

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

180.401, 180.403, 180.407(c)

Regulation Sections

Section Subject
180.401 Applicability
180.403 Definitions
180.407 Requirements for test and inspection of specification cargo tanks