Interpretation Response #24-0086
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Paul Akers Inc.
Individual Name: Mr. Alan Campbell
Location State: IN Country: US
View the Interpretation Document
Response text:
December 16, 2024
Mr. Alan Campbell
Paul Akers Inc.
3155 West US 40
Greenfield, IN 46140
Reference No: 24-0086
Dear Mr. Campbell:
This letter is in response to your September 17, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to transporting anhydrous ammonia or liquified petroleum gas in MC 330 and MC 331 cargo tanks. In your email, you ask whether these MC 330 and MC 331 cargo tanks qualify for a leakage test at 60 psi because they are used for transporting anhydrous ammonia or liquified petroleum gas depending on the time of the year.
The answer is no. As referenced in §§ 180.407(h)(1)(ii) and (iv), both paragraphs state that MC 330 and MC 331 cargo tanks are required to be in dedicated service to either liquefied petroleum gas or anhydrous ammonia. Shipping both materials interchangeably throughout the year is not considered to be in dedicated service and—therefore—§§ 180.407(h)(1)(ii) and (iv) do not apply.
I hope this information is helpful. If you have any more questions, please do not hesitate to contact this Office.
Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
180.407(h)(1)(ii) and (iv)