Operational Policy 15 - Missing Dust Cap

A DataQ challenge was done for a violation of 178.345-11(c) "SAFETY CAP FOR DISCHARGE LINE MISSING", documented by the Nevada Highway Patrol. The inspection report shows 178.345-11(b), but the officer responded to the DataQ explaining "Inspect does not allow us to input the exact violation, which is CFR178.345-11(c). The officer referenced the regulation "must be fitted with another stop-valve or other leak-tight closure at the end of such connection". No data correction was made. The DataQ was re challenged stating that there is an internal self-closing stop-valve and another stop-valve closure at the end of the connection. It was stated that the cap is a convenience to the driver/carrier as its intention is to keep foreign objects, dust, road grime, snow, etc., out of the discharge line connection area. Picture titled "PICTURE OF EXTERNAL VALVE", with an arrow to the valve handle was attached. This challenge was denied with the following reason: "According to CFR178.345-11(c) the unloading pipe must be fitted with a leak-tight closure." The whole regulation was stated again and 2 photos of the officers body camera were submitted, showing the missing cap.

The discharge pipe "Dust Cap/Safety Cap" is not a stop-valve or other leak-tight closure at the end of the discharge pipe. The discharge pipe has a stop-valve just before the discharge pipe hose connection. The cap is a convenience to the driver/carrier as its intention is to keep foreign objects, dust, road grime, snow, etc., out of the discharge line connection area. Attached are pictures of the "PICTURE OF EXTERNAL VALVE" and the officers body cam pictures, with arrows that I have placed showing the external valve handles.

Requesting the committee rule that the missing "Dust Cap" is not a violation. Suggest adding this situation to Ops Policy 15.