What a regulatory nightmare. So, I’ll reply to my own question. Yes, Coaldust. If the PHMSA people issued you an “M” number, you can inspect UN portable containers all day long and holidays.
But, what if I put it on a boat and ship it to Seattle? Well then CFR 452.3 applies.
(3) each exam must be performed by qualified personnel, trained and experienced the detection of structural damage.
WTF does that mean? Is there a school or credential for that? Or, is it based upon self certification? Can I provide some training and claim my employee is trained and experienced?
Where does the intermodal container CSC Safety Survey fall into this? Who can do CSC surveys? Is a current CSC even required for domestic transport? The rules only say export. Should I even care what the IMO says? There office is in London. They don’t have any way to enforce regulatory compliance on me.
The struggle continues,......