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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #98-0281 ([Safe Delivery System, L.L.C. (SDS] [Mr. Daniel R. Meyer])

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

Interpretation Response Details

Response Publish Date:

Company Name: Safe Delivery System, L.L.C. (SDS

Individual Name: Mr. Daniel R. Meyer

Location State: IA Country: US

View the Interpretation Document

Response text:

NOV 6, 1998


Mr. Daniel R. Meyer                     Ref. No.: 98-0281
Safe Delivery System, L.L.C. (SDS)
404 North Main
Qulimby, Iowa 51049

Dear Mr. Meyer:

This responds to your letter of September 8, 1998, concerning cargo tank requirements under the Hazardous Materials Regulations (HMRi 49 CFR Parts 171-180). You ask whether a system that detects shear or separation within the vehicle pumping system and
automatically shuts the internal self-closing stop valve satisfies the requirement in § 178.337-11(a) (1) (i).

The answer to your question is "yes." The specification requirements for emergency discharge control can be achieved by means of either an internal self-closing stop valve or an excess flow valve (see § 178.337-8(a) (2)}. Thus, if the ~DRM Safety System" will automatically close the internal self-closing stop valve in the event of shear or separation of piping or hose, then the system does conform to the performance standard in § 178.337¬11 (a) (1) (i).

You should be aware that the provisions of the HMR applicable to emergency discharge control systems are currently under discussion by a negotiated rulemaking advisory committee that was chartered to develop recommendations for alternative safety standards for preventing and mitigating unintentional releases of hazardous materials during the unloading of cargo tank motor vehicles in liquefied compressed gas service. Enclosed for your information is a copy of the Federal Register notice that established the advisory committee and outlined the issues it is
to consider. Also enclosed is a Federal Register notice announcing the advisory committee's meeting schedule.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards



Regulation Sections

Section Subject
178.337-11 Accident damage protection