ASME Design Code Effort Draws Fire
Feb 1, 2000 12:00 PM, mbt staff
An effort by the American Society of Mechanical Engineers (ASME) to develop an international cargo tank design code is drawing fire from all sides. The new code is being developed under ASME Section XII at the request of the Department of Transportation (DOT).
The next meeting on Section XII will be held February 28 and 29 at the Adams Mark Hotel in Daytona Beach, Florida. The Truck Trailer Manufacturers Association (TTMA) Tank Conference Engineering Committee will meet at the same location on February 29 and March 1, and Section XII will be on the agenda.
Jack Rademacher, Brenner Tank Inc, reviewed the current status of Section XII, and stated TTMA's position during the 1999 Cargo Tank Maintenance Seminar, which was held October 25-27 in Chicago, Illinois. The seminar was cosponsored by TTMA and National Tank Truck Carriers (NTTC). Widespread Opposition
TTMA wrote in a letter to the Secretary of Transportation that "we are vehemently opposed to any action, regulatory or otherwise, leading to the involvement of a third-party inspection agency everytime a DOT-specification tank is repaired or manufactured."
NTTC has stated that "should DOT involve any 'third-party' (such as ASME) in regulatory compliance, NTTC will demonstrate (in the courts, if necessary) that the agency is abdicating its congressionally mandated duty to enforce their regulations."
The negative response from Europe has been just as intense. Government officials from the European Union have stated that associations such as ASME have no regulatory jurisdiction. International standards are already coordinated through the United Nations.
Section XII of the ASME code is still under development, but it will cover cargo tank design and materials, fabrication and inspection, and general requirements for components such as valves and vents. It would affect manufacturers, repair shops, and users of specification tank trailers, intermodal tank containers, ton tanks, intermediate bulk containers, and others.
"ASME got involved because RSPA (Research and Special Programs Administration) does not want to be in the business of designing cargo tanks," Rademacher said. "DOT has asked ASME to provide a cargo tank code that DOT can reference.
"DOT and its agencies lack the resources to adequately enforce the hazardous materials regulations currently in place. One problem is that some repair shops are providing questionable repairs and/or are ignoring DOT regulations. Some shops don't even have current copies of the regulations."
DOT wants the new ASME code to be transparent. In short, the engineering association has been asked to provide a design code that does not change the way cargo tanks are currently designed. The ASME-compliant tanks should not be heavier or have different venting requirements.
Improved Clarity DOT is not seeking to increase safety by design, according to Rademacher. Instead, the objective is to improve safety through clarity of the design requirements, repair procedures, and quality-control inspections.
Design rules would be tightened-significantly in some cases. On the positive side, some gray areas probably would be cleared up. Noncircular tanks (elliptical petroleum tanks, for instance) would be most affected.
"ASME really doesn't understand these types of tanks," Rademacher said. Initial drafts of Section XII also call for third-party inspections. In addition to periodic audits to demonstrate code compliance, Section XII could call for a third-party review of every repair. "All of this could mean longer repair cycle times, a lot more paperwork, and higher repair costs," Rademacher said.
Third-party inspections are an inherent ASME requirement, he added. Not surprisingly, the inspection agencies have voiced strong approval. Rademacher pointed out that repair shops would pay up to $500 per visit for a third-party inspector. It would cost approximately $90,000 a year to employ a fulltime inspector.
RSPA has explained to TTMA and NTTC that the agency and DOT do not advocate third-party inspections for every repair. The federal government would prefer periodic ASME quality audit reviews. Officials acknowledge that the ASME position could cause problems, including unnecessarily higher repair costs and delays. And it is likely to encourage more unlawful repairs.
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