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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 #98-0363 ([National Tank Truck Carriers, Inc.] [Mr. Clifford J. Harvison, Jr.])

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

Interpretation Response Details

Response Publish Date:

Company Name: National Tank Truck Carriers, Inc.

Individual Name: Mr. Clifford J. Harvison, Jr.

Location State: VA Country: US

View the Interpretation Document

Response text:

JAN 19, 1999


Mr. Clifford J. Harvison, Jr.                 Ref. No. 98-0363
National Tank Truck Carriers, Inc.
2200 Mill Road
Alexandria, VA 22314

Dear Mr. Harvison:

This responds to your recent letter concerning certain cargo tank tests and inspections required under the Hazardous Materials Regulations (49 CFR Parts 171-180; HMR). Specifically, you ask about the elements of a pressure test and the procedures that should be followed if more than one facility performs the inspections and testing.

Your interpretation is correct. The pressure test required by § 180.407(g) of the HMR is not considered complete until both the external and internal inspections, as well as the pressure test, have been completed. An operator may use more than one facility to perform the required inspections and testing. In that event, as you have advised your members, the pressure test marking required by § 180.415 is applied to the cargo tank only when all inspection and testing requirements are fulfilled. Further, the relevant documentation must indicate that different facilities performed the external and internal inspections and the pressure test. Until the inspection and testing requirements are completed, the specification plate on the cargo tank should be covered. We advise against removing the specification plate in this situation.

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
180.407 Requirements for test and inspection of specification cargo tanks