Interpretation Response #22-0121
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 Training Solutions
Individual Name: Arturo Prado
Location State: TX Country: US
View the Interpretation Document
Response text:
February 2, 2023
Arturo Prado
DOT Training Solutions
701 Briar Court
Brownsville, TX 78521
Reference No. 22-0121
Dear Mr. Prado:
This letter is in response to your November 4, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the configuration of bulk trailer valves. You ask whether a DOT 407 cargo tank motor vehicle (CTMV), manufactured as a "wheels back" vehicle, as defined in 49 CFR § 393.5, fitted with a rear loading valve located behind the fifth axle, and in full tow configuration is required to have an internal self-closing stop valve with a sacrificial device.
According to § 178.345-8 and when solely considering accident damage protection, an internal self-closing stop-valve with a sacrificial device is required only when seeking relief from § 178.3458(b)(1). When a sacrificial device is required, it is subject to the strength and location requirements found in § 178.345-8(b)(2). However, based on the photographs and information you provided, we are unable to make the determination whether the configuration presented meets the requirements of § 178.345-8(b)(1) or § 178.345-8(b)(2). Additionally, the CTMV is still subject to the remaining requirements found in § 178.345-8, as well as any other applicable requirements (i.e., tank outlet requirements found in § 178.345-11). These other requirements must also be taken into consideration when making a final determination for valve requirements.
Please note, this office does not make the determination whether specific individual configurations meet the applicable requirements of the HMR.
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
178.345-8, 178.3458(b)(1), 178.345-8(b)(2), 178.345-11
Regulation Sections
Section | Subject |
---|---|
178.345-11 | Tank outlets |
178.345-8 | Accident damage protection |