Although there is a general freeze on new regulations, the Pipeline and Hazardous Materials Safety Administration (PHMSA) was approved to issue HM-215N as a final rule. This rule updates the hazardous materials regulations to reflect changes in various international hazardous materials standards.
Called the “harmonization rule,” it normally does not affect cargo tanks, but this year is different. Section 180.413 has been amended to:
1) Authorize Canadian facilities to repair DOT-specification cargo tanks, and
2) It excepts Canadian registered facilities performing code tank repairs (not tests and inspections) from obtaining a US DOT CT#.
If a DOT-specification cargo tank motor vehicle is repaired in Canada after 1/1/2017, it may be done under Canada’s TDG regime, which allows the facility to obtain either the NBIC R stamp or a provincial authorization.
Under the TDG rules, there is no requirement for certification of the repair by a registered inspector.
Cargo tank owners still have to maintain records of repair, but if the repair was done by a Canadian facility with a provincial authorization, the paperwork will be different than what is normally seen with an NBIC R Stamp repair.
The rule also authorizes transportation under Transport Canada’s Equivalency Certificates (similar to a DOT Special Permit) into the United States.