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Interpretation Response #02-0065

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

Interpretation Response Details

Response Publish Date: 05-16-2002
Individual Name: Glen Gillaspia
Location state: TX    Country: US

View the Interpretation Document

Response text:

May 16, 2002

Mr. Glen Gillaspia                 Reference No. 02-0065
415 Lookout Lane
Dickenson, TX 77539

Dear Mr. Gillaspia:

This is in response to your February 25, 2002 letter concerning attendance requirements for rail tank car unloading under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180).  Specifically, you ask if you could have one camera monitor two tank cars by switching the video image from one car to the other every ten seconds.

The arrangement you describe does not conform. to the monitoring requirements of § 174.67(i) which requires a tank car to be continuously attended throughout the entire period of unloading and while the tank car is connected to an unloading device.  Enclosed is a letter from Thomas Allan (Ref No. 99-0217) of our office which further clarifies this issue.

I hope this satisfies your request.


Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
§ 174.67 Tank car unloading