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)