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Interpretation Response #24-0030

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

Interpretation Response Details

Response Publish Date:

Company Name: Polar Service Centers

Individual Name: Mr. Marv Miller

Location State: OR Country: US

View the Interpretation Document

Response text:

October 16, 2024

Mr. Marv Miller
Director, Technical Operations—Compliance
Polar Service Centers
8801 North Vancouver Avenue
Portland, OR  97217

Reference No. 24-0030

Dear Mr. Miller:

This letter is in response to your May 24, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to United Nations (UN) portable tank inspections. Specifically, you ask about the applicability of your company's competent authority approval (CAA) when portable tanks inspected by your company are transported internationally.

The International Maritime Dangerous Goods (IMDG) Code requires inspections and tests for portable tanks to be performed or witnessed by experts approved by the competent authority or its recognized body—see IMDG Code 6.7.4.14.10. The United States recognizes designated approval agencies through the issuance of an approval as a Designated Approval Agency (DAA), please see 49 CFR Part 107, Subpart E. Each DAA approval indicates the types of inspections the DAA is approved to perform and on what types of tanks. Polar Service Centers holds a CAA (CA2006010015) which authorizes, among other things, the periodic testing of UN portable tanks and periodic testing and inspections of existing Department of Transportation (DOT) Intermodal (IM) specification IM 101 and IM 102 portable tanks. This CAA, issued under 49 CFR § 107.402 to Polar Service Centers, allows the DAA to conduct periodic inspections on UN portable tanks. It is not dependent on the portable tanks being inspected and originally approved in a particular country or region and applies to all portable tanks covered by the approval.

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

Sincerely,

Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

107.402

Regulation Sections

Section Subject
107.402 Application for designation as a certification agency