Interpretation Response #14-0229
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Ms. Robyn Kinsley
The Chlorine Institute
1300 Wilson Blvd., Suite 525
Arlington, VA 22209
Reference No. 14-0229
Dear Ms. Kinsley:
This is in response to your November 18, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to a tell-tale indicator on a combination pressure relief device for a rail tank car. You ask if, in accordance with HMR § 179.100-13(a) the outlet for a tell-tale indicator which has a threaded outlet must be closed with an approved screw plug during transportation.
The requirement to close a tell-tale indicator having a threaded outlet with an approved screw plug does apply. The requirements for pressure relief devices are found in HMR § 179.15. For a combination pressure relief system, § 179.15(e)(2) requires that a tell-tale indicator be closed during transportation. The combination pressure relief system designed with a tell-tale indicator must be in compliance with the AAR approved design when utilizing a screw plug in the closed position.
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
|§ 179.15||Pressure relief devices|