Interpretation Response #15-0201 ([Arkema] [Ms. Christina Kurtz])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 12/09/2015

Company Name: Arkema

Individual Name: Ms. Christina Kurtz

Location State: PA Country: US

View the Interpretation Document

Response text:

December 09, 2015

Ms. Christina Kurtz
Manager of Regulations and Packaging
Health, Environment, and Safety
Arkema
900 First Avenue, Building #2
King of Prussia, PA  19406

Reference No.  15-0201

Dear Ms. Kurtz:

This responds to your October 8, 2015 email concerning a final rule under Docket No. PHMSA-2012-0082; HM-251 (80 FR 26643).  Specifically, you request confirmation that the requirements adopted in this final rule do not apply to materials with a subsidiary hazard of  Class 3 flammable liquid.

Your understanding is correct.  On May 8, 2015, the Pipeline and Hazardous Materials Safety Administration, in coordination with the Federal Railroad Administration, issued a final rule, entitled “Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains.” In the rule, PHMSA adopted enhanced tank car standards and operational controls for high-hazard flammable trains.  As used in the final rule,  Class 3 refers to the primary hazard or hazard class of the material as indicated in Column (3) of the Hazardous Materials Table in 49 CFR 172.101.

I trust this satisfies your inquiry.  Please feel free to contact me if you need further assistance.

Sincerely,

Ben Supko
Senior Regulations Officer
Standards and Rulemaking Division

172.101

Regulation Sections