TANK truck carriers who perform significant cargo tank maintenance and repair in their own shops can expect a new Research and Special Programs Administration (RSPA) rule (HM-213) to impact their operations, says Cliff Harvison, National Tank Truck Carriers president.
“However, while this docket represents the most comprehensive rewrite of RSPA's cargo tank regulations in over a decade, it is important to note that the vast majority of the new rules will apply to cargo tank manufacturers and those who test, inspect, and repair specification equipment,” Harvison says.
“In other words, the impact on a carrier will vary. If all you do is run trucks, that impact will be minimal. If, however, you also do your own tank testing, inspections, repairs and modifications, the new requirements will be substantial.”
The new rule, published in the “Federal Register” April 18, affects the construction and maintenance of cargo tank motor vehicles. It goes into effect October 1, 2003. RSPA has updated and clarified regulations contained in 49 CFR Parts 107, 171, 172, 173, 177, 178, and 180. Voluntary compliance is authorized 30 days after the publication date.
Revisions applicable to all cargo tanks include the marking of emergency shutoff devices, recertification to original specification, and cargo tank qualification and maintenance.
Revisions applicable to DOT 400-series include structural integrity requirements, manhole marking, road clearance, maximum allowable working pressure (MAWP), leak testing using Environmental Protection Agency (EPA) Method 27, and weld joints on DOT407 cargo tanks.
Other revisions include those applicable to MC331 and MC338 cargo tanks, such as consistency with DOT 400-series specification, remote shutoffs, MC331 inlet and outlet fittings, visual inspections for insulated vessels, and leakage tests for tanks hauling anhydrous ammonia.
The final rule also effects design certifying engineers and registered inspectors. It will permit an individual who does not meet the educational requirements in the definitions to be recognized as a certifying engineer or inspector if the person was performing those functions for three years prior to September 1, 1991. In addition, the final rule eliminates a previous requirement for an individual to have registered with DOT before December 31, 1995.
The final rule has taken almost a year and one-half to be realized. The proposal was published in the “Federal Register” December 4, 2001.
For more information about the final rule, contact Michael Johnsen at 202-366-6121, Philip Olson at 202-366-4504, Susan Gorsky at 202-366-8553; or Danny Shelton at 202-366-6121, at RSPA.
The rule in its entirety can be read on the Internet in the “Federal Register” by going to access.gpo.gov, scroll to the bottom of the page and under “executive resources” click on the “Federal Register” button. The rule is under the April 18 entries.