Interpretation Response #04-0286 ([Kenan Advantage Group, Inc] [Mr. Bruce Redmon])

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

Interpretation Response Details

Response Publish Date: 02/28/2005

Company Name: Kenan Advantage Group, Inc

Individual Name: Mr. Bruce Redmon

Location State: CA Country: US

View the Interpretation Document

Response text:

Feb 28, 2005

Mr. Bruce Redmon                Reference No. 04-0286
Kenan Advantage Group, Inc
4076 Seaport BLVD
West Sacramento, CA 95691

Dear Mr. Redmon:

This is in response to your letter dated December 14, 2004, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask how much gasoline or diesel fuel you may unintentionally release during the hookup and breakdown of loading and unloading hoses before being required to submit a 1-lazardous Materials Incident Report (171.16).

Pursuant to § 171.16, each person in physical possession of a hazardous material must submit a written or electronic report., using DOT Form F 5800.1, within thirty days of the date of discovery of a reportable incident as defined in § 171.15(b) or when any of the conditions set forth in § 171.16(a)(1)-(4) us met. There are exceptions to release reporting in § 171.16(d) provided the incident is not otherwise subject to immediate telephone notification. For example, the incident reporting requirements do not apply to minimal amounts of hazardous materials (i.e., a pint or less) escaping: (1) from a vent for materials for which venting is authorized; (2) from the routine operation of a seal, pump, compressor, or valve; or (3) from the connection or disconnection of loading or unloading lines, provided the release does not result in property damage (171.l6 (d)(1)).

I hope this satisfies your request.

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

171.16

Regulation Sections