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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.


Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions