Specification Cargo Tanks Weighing Greater Than Allowed

Specification Cargo Tanks loaded to a weight greater than allowed per the max lading as indicated on the spec plate to be placed OOS as an unauthorized/non-spec. package.

The OOSC states that “An out-of-service condition exists when transporting HM/DG in a bulk package not authorized for the material being transported. Unless otherwise indicated herein, specification shortages shall not disqualify an otherwise authorized package.” I believe that loading a spec. CT to a weight greater than what a Certified Design Engineer (CDE) is stating that said CT was certified and designed for, is not a “spec. shortage”. It now places stresses on the package welds, anchors, supports and other structural aspects that are beyond the specification design and thus making the package “non-spec”. You could relate this to opening a non-bulk package and not reclosing to the same standard in which it passed POP testing. Since that package is no longer in the condition it was in when it passed POP testing, then it is no longer a UN spec package. Furthermore we can continue the argument by pointing at the OOSC for tire weight rating “Weight carried exceeds tire load limit.” Tire manufactures, backed by their engineers, have concurred that exceeding the “designed load rating” is an imminent hazard, so can be said of the CDE’s max lading designation for any given CT specification design. If a DOT Specification Bulk Package, e.g. MC 306 or DOT 406 is filled to a level that “…exceeds the maximum weight of lading marked on the specification plate.”, as prohibited in 173.24b(d)(2), and now exceeds the design specifications certified by the CDE, said bulk package could be considered out of specification and thus a non-DOT specification package? 180.405(b) states “(b) Cargo tank specifications. (1) To qualify as an authorized packaging, each cargo tank must conform to this subpart, the applicable requirements specified in part 173 of this subchapter for the specific lading, and where a DOT specification cargo tank is required, an applicable specification in effect on the date initial construction began”. With this section and 173.24b(d)(2), it would appear that if a DOT Specification Package is filled to a weight greater than the maximum weight stated on the required specification plate, then said package would be an “unauthorized package” and if the package is unauthorized due to exceeding its design specifications, then the package would be considered a “non-DOT Specification” package.

Place a new “Note” in the OOSC that states “Exceeding the maximum lading as specified on the certification, data or specification plate, would render said bulk package an unauthorized package or a non-specification package.