Operational Policy 4 - Certification and Maintenance of Cargo Tank Inspections

CVSA Operational Policy 4, related to the certification and maintenance of cargo tank inspections, could be more clear as to whether cargo tanks used to haul elevated temperature material count as certification or maintenance.

While the tanks used to haul elevated temperature material such as asphalt are not built to a fully compliant MC, DOT, CGA or other code, they do have specific requirements in the regulations related to cargo tanks in Part 178. UN3257, Elevated temperature liquid, n.o.s., at or above 100 C and below its flash point (including molten metals, molten salts, etc.), directs the user to 173.247 for package authorization. For cargo tanks, the package authorization for non-spec tanks includes parts of 178.345, a cargo tank specification code: "...and non-DOT specification cargo tank motor vehicles equivalent in structural design and accident damage resistance to specification packagings. A non-DOT specification cargo tank motor vehicle constructed of carbon steel which is in elevated temperature material service is excepted from § 178.345-7(d)(5) of this subchapter." It seems counter intuitive that a 5-gallon gasoline or diesel can, or one small cylinder of compressed gas shipped as materials of trade counts as credit, but a cargo tank still required to display some markings, with specific Part 173 and 178 requirements, does not count for certification or maintenance.

I would like the training and hazmat committees to discuss this issue, and if they agree these types of "non-spec" tanks used for elevated temperature material count for CTI credit, the policy be updated to clearly reflected that they satisfy certification or maintenance requirements. Suggested language in the pre-existing policy in capital letters at the end of the paragraph: As of Sept. 19, 2007, to maintain certification to conduct North American Standard Cargo Tank Inspections, at least eight inspections shall be conducted on vehicles transporting hazardous materials/dangerous goods in bulk quantities in specification cargo tanks or DOT-SP cargo tanks (specification cargo tanks are not limited to DOT or MC series tanks but also may include CGA, ASME, TC, vehicles operated under IME-SLP 23, or other cargo tanks built to specification codes INCLUDING CARGO TANKS USED IN THE TRANSPORTATION OF ELEVATED TEMPERATURE MATERIALS AND BUILT TO PORTIONS OF PART 178).