Interpretation Response #15-0139 ([A.I.D. Inc.] [Mr. Donald Brittingham])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: A.I.D. Inc.
Individual Name: Mr. Donald Brittingham
Location State: MD Country: US
View the Interpretation Document
Response text:
December 09, 2016
Mr. Donald Brittingham
A.I.D., Inc.
208 143rd Street
Ocean City, MD 21842
Reference No. 15-0139
Dear Mr. Brittingham:
This letter is in response to your July 6, 2015, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked if 49 CFR § 173.31 requires shippers of tank cars containing hazardous materials or the residue of a hazardous material to inspect the tank car’s “running gear components (wheels, axles, brake system components, bolsters, side frames, etc.)” and all other tank car fittings like “sill steps [and] grab irons couplers” for defects prior to offering the tank car for transportation.
Generally, the HMR do not require an offeror of a tank car to inspect the tank car’s running gear components or safety appliances (as identified by 49 CFR Part 231) for defects prior to offering the tank car into transportation. However, § 173.31 prohibits the offering of a tank car unless it meets the applicable specification and packaging requirements of the HMR, and paragraph (d) of § 173.31 sets forth the minimum requirements for an offeror’s external visual inspection of a tank car being offered into transportation. Regarding the coupling gear, paragraph (d)(1)(viii) of § 173.31 specifically requires an offeror to examine, among other things, a tank car’s coupler vertical restraint system for conditions that make the tank car unsafe for transportation.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.31
Regulation Sections
| Section | Subject |
|---|---|
| 173.31 | Use of tank cars |