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Interpretation Response #06-0198 ([DuPont Global Logistics] [Mr. Kevin M. Greene])

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

Interpretation Response Details

Response Publish Date:

Company Name: DuPont Global Logistics

Individual Name: Mr. Kevin M. Greene

Location State: AL Country: US

View the Interpretation Document

Response text:

Mar 20, 2007


Mr. Kevin M. Greene                 Reference No. 06-0198
Hazardous Materials
    Distribution Consultant
DuPont Global Logistics
P.O. Box 525
Axis, Alabama 36505

Dear Mr. Greene:

This responds to your letter requesting clarification of the tank car loading and unloading signage requirements under the Hazardous Materials Regulations (HMR; 49 C Parts 171-180) Specifically, you ask whether caution signs placed either on the tracks or tank cars as specified n § 174.67(a) (4) would satisfy the requirement in § 173.31(g) (2) that specifies that caution signs must be placed between the rails.

The answer to your question is yes. We did not intend to restrict placement of caution signs in § 173.31(g). You may place caution signs on the track or the tank car to satisfy the re in § 173.31(g) (2). T underlying requirement in both sections of the HMR is that adequate warning be given to persons operating equipment that might, if it struck the end of a car being loaded or unloaded, cause personal injury. Placing caution signs between the rails does not preclude placing them on the car; “between the rails” is commonly understood among railroaders to mean anywhere within the vertical plane of the gauge of the track. As a general rule, the usual way to comply with either paragraph is to place a derail on the track between the car and the open end of the track and to have a sign hanging on a pole extending upward from the derail that serves as the caution sign. We will correct the inconsistency of the language in § 173.31(g) (2) in a future rulemaking.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.




Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

173.31(g), 174.67(a)(4)

Regulation Sections

Section Subject
173.31 Use of tank cars
174.67 Tank car unloading