DOT Incorporation of Section XII Update

Author’s note: this really isn’t much of an update, but since work continues and things are still pending, I felt it appropriate to say SOMETHING about what’s going on!)

ASME published B&PV Code Section XII “Rules for Construction and Continued Service of Transport Tanks” in 2004. This was a response to a request from the DOT back in the late ’90s. The idea was that DOT wanted to get out of the business of including technical requirements in the 49 CFR, which
makes all the sense in the world. However, between the time the request was made and the rules were written, apparently, this desire lost priority.

The DOT has done some rulemaking activity (most recently in 2016, as you can read about here).  In the years since, there hasn’t been much word about it. Officially, the DOT CAN’T say anything (they cannot comment on such things once active/pending rulemaking is “in progress”). So, periodic inquiries have been made by various parties. In March of this year, the DOT indicated in a letter to ASME that they “are actively working to complete and publish the final rule”. Honestly, I really don’t know what to make of this, since they’ve been saying the same thing more or less since 2016. But I guess that means it
might still happen.

What would Section XII mean to the industry? Lots of things. If you look at the comments/questions to the rulemaking (here), you can see lots of different takes on how this would affect the industry. Some
folks are concerned about a more prevalent role for the National Board. Others are concerned about the fact that allowing both Section XII and VIII-1 construction would complicate both manufacturing and continued service. While I don’t really disagree with any of the criticisms, my personal viewpoint
(admitted skewed due to my own participation in the development process) is that Section XII is a marked improvement for all cargo tanks. The rules are clearer, more modern and take advantage of some of the changes in material production and fabrication methods that are lacking in the current rules.

Want to know more about it? Let me know!