Interpretation Response #98-0592 ([Mr. Roy E. Hanson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Roy E. Hanson
Location State: CA Country: US
View the Interpretation Document
Response text:
MAY 8, 1998
Mr. Roy E. Hanson, President
Roy E . Hanson, Jr., Mfg.
1924 Compton Avenue
Los Angeles, CA 90011
Dear Mr. Hanson:
This is in response to your letter concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR parts 171 - 180) for specification MC 331 cargo tank motor vehicles. You state that you manufacture cargo tanks exclusively for transportation of propane. Your understanding of the specification for cargo tanks having a capacity of3500 gallons or less is that a manhole is not required if the cargo tank is constructed of other than quenched and tempered steel (NQT). In addition, your understanding of the specification is that there is no requirement for an inspection opening, as provided by paragraph UG-46 of the American Society of Mechanical Engineers (ASME) Code, since propane is not corrosive to steel.
Your understanding of the HMR is not correct. Section 178.337-6(a) specifies that each cargo tank marked and certified after April 21, 1994, must be provided with a manhole conforming to paragraph UG-46 and other applicable requirements of the ASME Code. However, if the cargo tank is less than 3500 gallons and is constructed ofNQT steel, it may be provided with an inspection opening conforming to UG-46 and other applicable requirements of the ASME. Therefore, if the cargo tank is constructed ofNQT steel and has a capacity of3500 gallons or less, the tank must be equipped with either a manhole or an inspection opening. Although, the ASME does not require an inspection opening, it is required by specification MC 331.
I apologize for the delay in preparing this response and hope that it has not caused you any inconvenience. If you need further assistance, please contact us.
Sincerely,
Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards
178.345-8, 178-337-6
Regulation Sections
| Section | Subject |
|---|---|
| 178.345-8 | Accident damage protection |