Interpretation Response #14-0092 ([Mr. Ben Sweat])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Ben Sweat
Location State: KS Country: US
View the Interpretation Document
Response text:
July 15, 2014
Mr. Ben Sweat
3939 N. Webb
Wichita, KS 67226
Ref. No.: 14-0092
Dear Mr. Sweat:
This is in response to your email dated May 8, 2014, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the § 173.31(g) requirements for the use of rail tank cars. You describe the process used by your facilities to load tank cars, whereby a string of railcars are connected to a facility operated trackmobile or motorized railcar mover throughout the loading process. The trackmobile is used to position each set of one or two tank cars in the string for loading.
You ask if the § 173.31(g)(1) requirement that access to the track must be secured to prevent entry by other rail equipment, including motorized service vehicles, applies to facility operated motorized vehicles such as the trackmobile used as described. You also ask if the trackmobile needs to be disconnected from the from the tank cars during loading and unloading operations.
Based on the information provided, it is the opinion of this office that the intent of § 173.31(g) is to warn rail crews of the general rail transportation system of the status of a particular rail car or series of rail cars on a facility’s rail system, and prevent them from attaching to or moving the rail cars when it is unsafe to do so. This regulation is not intended to apply to facility operated motorized vehicles that are being used to move and position tank cars in support of loading and unloading operations. Further, § 173.31(g) does not address whether such facility operated motorized vehicles may remain connected to tank cars during loading or unloading operations.
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division
173.31(g)
Regulation Sections
Section | Subject |
---|---|
173.31 | Use of tank cars |