Interpretation Response #13-0172 ([Attorney at Law] [Mr. Lawrence W. Bierlein])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Attorney at Law
Individual Name: Mr. Lawrence W. Bierlein
Location State: DC Country: US
View the Interpretation Document
Response text:
November 15, 2013
Mr. Lawrence W. Bierlein
Attorney at Law
1101 30th Street, N.W., Suite 500
Washington, D.C. 20007
Ref. No. 13-0172
Dear Mr. Bierlein:
This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to the marking of tank cars. Section 179.22 requires that tank cars be marked in accordance with Appendix C of the Association of American Railroads (AAR) Specifications for Tank Cars (M-1002). Appendix C of AAR M-1002 requires that markings be stenciled on the tank car sides and ends. In your e-mail, you describe a scenario where a tank car is stenciled with required markings on both sides/ends and the top and ask if the redundant top marking is required to be maintained.
The answer is yes. Although the top marking is not required and is therefore redundant, any visible marking must be in accordance with the HMR. We recommend you cover or remove any additional markings not consistent with the required markings prescribed by the HMR.
I trust this information is helpful. Please contact us if you require further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
179.22