Interpretation Response #24-0044
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 National Board of Boiler and Pressure Vessel Inspectors
Individual Name: Luis Ponce
Location State: OH Country: US
View the Interpretation Document
Response text:
March 4, 2025
Luis Ponce
Manager of Technical Services
The National Board of Boiler and Pressure Vessel Inspectors
1055 Crupper Avenue
Columbus, OH 43229-1183
Reference No. 24-0044
Dear Mr. Ponce:
This letter is in response to your May 29, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Department of Transportation (DOT) specification cargo tank repair requirements. Specifically, you state that the National Board of Boiler and Pressure Vessel Inspectors (NBBI) publishes its flagship publication—i.e., the National Board Inspection Code (NBIC)—every two years. You further state that the next edition—for 2025—will see a complete rewrite of Supplement 6 "Repair, Alteration, and Modification of DOT Transport Tanks," and that there will be changes to the pressure testing of repairs and alterations to line up with DOT requirements. You ask for clarification on whether "applicable manufacturing specification" means a DOT specification or another code of construction.
We have paraphrased and answered your questions as follows:
Q1. Does the phrase “applicable manufacturing specification” in § 180.413(b) refer to the original code of construction, such as the American Society of Mechanical Engineers (ASME) Code?
A1. No. As specified in § 180.413(b), the suitability of each repair affecting the structural integrity or lading retention capability of the cargo tank must be determined by the testing required either in the applicable manufacturing specification or in § 180.407(g)(1)(iv). The phrase "applicable manufacturing specification" means the authorized DOT specification.
Q2. If the answer to Q1 is yes, can the requirements of either the original code of construction or Part 180 be used for repairs by an NBBI "R" stamp certificate holder?
A2. See answer A1.
We 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
180.407(g)(1)(iv), 180.413(b)