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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: 05-16-2023
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
§ 180.407 Requirements for test and inspection of specification cargo tanks