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Interpretation Response #10-0206 ([Iowa Renewable Fuels Association] [Mr. Monte Shaw])

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

Interpretation Response Details

Response Publish Date:

Company Name: Iowa Renewable Fuels Association

Individual Name: Mr. Monte Shaw

Location State: IA Country: US

View the Interpretation Document

Response text:

December 15, 2010

 

 

Mr. Monte Shaw

Executive Director

Iowa Renewable Fuels Association

5505 NW 88th Street, #100

Johnston, IA 50131

Ref. No.: 10-0206

Dear Mr. Shaw:

This responds to your September 24, 2010 letter requesting clarification of the pre-transportation functions under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You indicate that one of your ethanol and biodiesel member producers receives methanol in a tank car, unloads the methanol, closes the valve or lid, and returns the placarded tank car containing a possible residue of the methanol. Specifically, you ask if closing the valve or lid, as described above, is considered "securing a closure" under § 171.1(b)(4) or if it means sealing the package to prevent tampering.

As used in § 171.1(b)(4), the phrase "securing a closure" would apply to a person who closes the valve or lid on a package or container containing a residue of hazardous material. It does not refer to sealing a package to prevent tampering.

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

Sincerely,

Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division

171.1(b)(4)

Regulation Sections