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Interpretation Response #12-0267 ([Allied Universal Corporation] [Ms. Robin Bolte])

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

Interpretation Response Details

Response Publish Date:

Company Name: Allied Universal Corporation

Individual Name: Ms. Robin Bolte

Location State: FL Country: US

View the Interpretation Document

Response text:

May 6, 2013


Ms. Robin Bolte
Regulatory Affairs Manager
Allied Universal Corporation
3901 NW 115th Avenue
Miami, FL 33178

Ref. No.: 12-0267

Dear Ms. Bolte:

This responds to your December 11, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Multi-Unit Tank Cars.  In your letter, you state that your company performs hydrostatic tests on Multi-Unit Tank Car tanks and that your testing facility is authorized to perform hydrostatic testing for tank cars by a third party.  You state that you stamp the tank with the date tested when you perform hydrostatic testing on tank cars.  However, you do not put your Requalifier Identification Number (RIN) number on the tanks since the Multi-Unit Tank Cars are not considered cylinders.  You add that you do not adhere to the American Association of Railroads (AAR) Appendix R, as it is not applicable to Multi-Unit Tank Cars.  You ask how companies can be compliant with testing and tank car requalification requirements in the HMR when the AAR document referred to in § 179.6 does not include the Department of Transportation (DOT) specification container for Multi-Unit Tank Cars?

The Pipeline and Hazardous Materials Safety Administration (PHMSA) recognizes that a gap currently exists in the HMR for the testing and requalification of Multi-Unit Tank Cars.  Currently PHMSA issues a special permit (SP-15647) for companies that test and requalify Multi-Unit Tank Cars, and is allowing companies to apply for party status to this special permit.  Section 107.107 of the HMR specifies the requirements for a company to apply for party status of a special permit.  Obtaining party status to this special permit will allow companies to reauthorize and qualify Multi-Unit Tank Cars under the HMR.  PHMSA may consider a regulatory approach to address the issue in the future.

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

107.107, 171.1, 179.6

Regulation Sections

Section Subject
107.107 Application for party status
171.7 Reference material
179.6 Repairs and alterations