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Interpretation Response #06-0114

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

Interpretation Response Details

Response Publish Date: 07-11-2006
Company Name: Musket Corporation    Individual Name: Mr. Doug Lumry 
Location state: OK    Country: US

View the Interpretation Document

Response text:

Jul 11, 2006


Mr. Doug Lumry                Reference No. 06-0114

Manager of Rail Logistics
Musket Corporation
P.O. Box 26210
Oklahoma City, OK 73126

Dear Mr. Lumry:

This responds to your letter of May 9, 2006, requesting clarification of requirements for unloading hazardous materials from rail tank cars under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Specifically, you ask about requirements for opening manhole covers in accordance with § 174.67 of the HMR.

Rail tank car unloading operations conducted by consignee personnel after the tank car has been delivered to the consignee generally are not subject to regulation under the HMR because such operations occur after transportation has been completed. Thus, the requirements in § 174.67 do not apply to rail tank car unloading operations performed by consignee personnel after delivery of the tank car. The requirements in § 174.67 apply to transloading operations only. Transloading is the transfer of a hazardous material from one bulk packaging to another bulk packaging, from a bulk packaging to a non-bulk packaging, or from a non-bulk packaging to a bulk packaging for the purpose of continuing the movement of the hazardous material in commerce (see § 171.8).

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



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


Regulation Sections

Section Subject
§ 174.67 Tank car unloading