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Interpretation Response #24-0022

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

Interpretation Response Details

Response Publish Date:

Company Name: The Hartford Steam Boiler Inspection and Insurance Company

Individual Name: Timothy Nuoffer

Location State: CT Country: US

View the Interpretation Document

Response text:

January 2, 2025

Timothy Nuoffer
Supervisor Code Services
The Hartford Steam Boiler
Inspection and Insurance Company
One State Street
P.O. Box 5024
Hartford, CT  06102

Reference No. 24-0022

Dear Mr. Nuoffer:

This letter is in response to your March 20, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to offshore portable tanks. In your email, you note that The Hartford Steam Boiler (HSB) is a designated approval agency (DAA) for the new manufacture and periodic testing of United Nations (UN) portable tanks—including UN portable tanks approved and certified under Chapter 6.7 of the International Maritime Dangerous Goods (IMDG) Code. You add that the approval document that authorizes HSB to perform this activity—CA20030400011 —does not specifically address offshore portable tanks as defined in § 178.274(a)(3). Specifically, you ask about HSB's DAA authority and whether it includes approval and certification of UN portable tanks for offshore service in accordance with Chapter 6.7 of the IMDG Code.

1 https://www.phmsa.dot.gov/hazmat/documents/approval/1_CA2003040001_2021104386.pdf/ApprovalsCA_19718_CAApproval-5d365c8c-91fa-4f00-8642-c55bd89fc2a9

The answer is no; however, approval specific to such offshore service is not required by the HMR. HSB's approval allows for the certification of newly manufactured and periodic retesting of UN portable tanks, as well as the periodic testing and inspections of existing Department of Transportation specification intermodal (IM) 101 and IM 102 IM portable tanks. Offshore portable tanks are portable tanks meeting the Guidelines for the Approval of Containers Handled in Open Seas specified in the IMDG Code (MSC.1 Cir.860) and marked "OFFSHORE PORTABLE TANK" on the identification plate. The certification of an offshore portable tank's design, manufacture, testing, and/or inspection for compliance with MSC.1 Cir.860 is not required to be authorized by PHMSA. As a result, DAA's that certify and/or test offshore portable tanks may do so independently of a DAA approval with PHMSA.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

178.274(a)(3)

Regulation Sections