Interpretation Response #06-0235 ([Railroad Commission of Texas] [Mr. James T. Osterhaus ])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Railroad Commission of Texas
Individual Name: Mr. James T. Osterhaus
Location State: TX Country: US
View the Interpretation Document
Response text:
Nov 16, 2006
Mr. James T. Osterhaus Reference No. 06-0235
LPG Section Manager, Safety Division
Railroad Commission of Texas
1701 North Congress Avenue
Austin, TX 78711-2967
Dear Mr. Osterhaus:
This responds to your letter dated October 18, 2006, regarding the NON-ODORIZED or
NOT-ODORIZED marking on packagings containing unodorized Liquefied Petroleum
Gas (LPG) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Under the HMR, a NON-ODORIZED or NOT-ODORIZED marking is required to be displayed on certain cylinders, portable tanks, cargo tanks, and tank cars and multi-unit tank car tanks containing LPG that is shipped unodorized in transportation in commerce (see § 172.301, 172.326, 172.328, and 172.330, respectively).
You are correct that as of October 1, 2006, the NON-ODORIZED or NOT-ODDRIZED marking may appear on a tank car or multi-unit tank car tank used for both unodonzed and odorized LPG, as specified in § 172.330. Although the requirements for marking a cargo tank do not specify that the marking may be displayed on a cargo tank used for both unodorized and odorized LPG, such display is not prohibited in accordance with the prohibited marking in § 172.303. Thus, the NON-ODORIZED or NOT-ODORIZED marking may appear on a cargo tank used for both unodorized and odorized LPG.
As a result of interest from the regulated community in prescribing requirements for display of the NON-ODORIZED or NOT-ODORIZED marking on a cargo tank used for both unodonzed and odorized LPG, we intend to revisit this issue in a future rulemaking in order to specify similar requirements currently allowed for tank cars and multi-unit tank car tanks for certain cylinders, cargo tanks, and portable tanks.
I hope this satisfies you inquiry. If we can be of further assistance, please contact us.
Sincerely,
John A. Gale
Chief, Regulations Development
Office of Hazardous Materials Standards
172.303, 172.328
Regulation Sections
| Section | Subject |
|---|---|
| 172.303 | Prohibited marking |
| 172.328 | Cargo tanks |