Field Repairs on DOT and non-DOT Specification Cargo Tanks

This is in response to your letter dated July 22, 1992, to Philip Olson in the Office of Hazardous Materials Technology concerning field repairs on certain DOT specification and non-DOT specification cargo tanks (airport refuelers).

The definition of "repair" as it applies to cargo tanks is found in Title 49, Code of Federal Regulations (49 CFR) Section 180.403. In part, that section states that the term "repair" applies to welding on the cargo tank wall, the primary lading retention structure. Repairs on non-DOT specification cargo tanks are not covered by 49 CFR. Since June 30, 1992, any person undertaking repairs on DOt specification cargo tanks has been required to:

a. hold a valid ASME Certification of Authorization for use of the "U" stamp, or a valid
National Board Certification for the use of the "R" stamp, and
b. be registered in accordance with Subpart F of Part 107 of 49 CFR.

Field repairs are not authorized by the National Board of Boil and Pressure Vessels Inspectors unless the Certificate of Authorization for the use of the "R" stamp specifically authorizes field repair activity. For reference, this is in accordance with the 1983 National Board Inspection Code (NBIC) Appendix C-R, page 135, copy enclosed. We have recently learn d that the 1992 edition of the NBIC has deleted the provision for repairs and alterations to be performed by holders of the ASME "U" stamp.

You also expressed concern as to whether cargo tank motor vehicles which are not used on the highway must be inspected in accordance with the requirements of 49 CPR. Non-DOT specification cargo tanks are not subject to the retest and inspection requirements specified in 49 CFR Part 180. However, any cargo tank marked as a DOT specification packaging must be maintained in accordance with 49 CFR Part 180 Subpart E, whether or not it is used or intended to be used for hazardous materials.

If you have further questions, please feel free to contact us.