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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #06-0058 ([Ferreilgas] [Mr. Ross Warnell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Ferreilgas

Individual Name: Mr. Ross Warnell

Location State: MI Country: US

View the Interpretation Document

Response text:

May 31, 2006

 

Mr. Ross Warnell                Reference No. 06-0058
Technical Standards and Procedures Manager
Ferreilgas
One Liberty Plaza
Liberty, Ml 64068

Mr. Warnell:

This is in response to your letter requesting clarification of tank car unloading requirements provided in § 173.3 1(g) of the Hazardous Materials Regulations (F1MR; 49 CFR Parts 171- 180). Specifically, you ask if a steel gate or a steel locking arm may be used to satisfy § 173.3 1(g)(1), requiring the unloader to secure access to the track to prevent entry by other rail equipment.

In accordance with § 173.3 1(g)(1), examples of devices capable of securing access to the track and preventing entry by other rail equipment would be derails, lined and blocked switches, portable bumper blocks, and other equivalent equipment. For equipment to be equivalent to those specifically mentioned by example, it must be capable of protecting the unloading operation by diverting or stopping rail equipment. In our opinion, a locked gate or a steel gate arm or other formidable barrier capable of stopping or diverting rail equipment and providing the same level of protection as a portable bumping block, derail, switch or similar device would fulfill the requirements of 173.3 .1(g)(1).

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

 

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

173.31(g)(1)

Regulation Sections

Section Subject
173.31 Use of tank cars