Interpretation Response #22-0138
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: AllTranstek, L.L.C.
Individual Name: Mike Tait
Location State: IL Country: US
View the Interpretation Document
Response text:
January 19, 2023
Mike Tait
Director
AllTranstek, L.L.C.
1101 W. 31st Street, Suite 200
Downers Grove, IL 60515
Reference No. 22-0138
Dear Mr. Tait:
This letter is in response to your December 14, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the protection against shifting or coupling of tank cars placed for loading or unloading by blocking and setting of the hand brake(s). Specifically, you ask whether the use of the SCAMP® rail car indexer—mechanized equipment placed along rails to move trains one or more cars at a time—may be used instead of blocking at least one wheel on a tank car and setting the hand brake in accordance with the requirements in § 173.31(g)(3).
The answer is no. The requirements of § 173.31(g)(3) specifically require a person to block at least one wheel on the tank car against motion in both directions and the hand brake must (emphasis added) be set. There is no prohibition in the HMR on using additional means to prevent motion of the tank car—such as the use of the SCAMP® railcar indexer—but the use of this device alone does not satisfy the requirements of § 173.31(g)(3).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
173.31(g)(3)
Regulation Sections
| Section | Subject |
|---|---|
| 173.31 | Use of tank cars |