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Interpretation Response #15-0201 ([Arkema] [Ms. Christina Kurtz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Arkema

Individual Name: Ms. Christina Kurtz

Location State: PA Country: US

View the Interpretation Document

Response text:

December 09, 2015

Ms. Christina Kurtz
Manager of Regulations and Packaging
Health, Environment, and Safety
900 First Avenue, Building #2
King of Prussia, PA  19406

Reference No.  15-0201

Dear Ms. Kurtz:

This responds to your October 8, 2015 email concerning a final rule under Docket No. PHMSA-2012-0082; HM-251 (80 FR 26643).  Specifically, you request confirmation that the requirements adopted in this final rule do not apply to materials with a subsidiary hazard of  Class 3 flammable liquid.

Your understanding is correct.  On May 8, 2015, the Pipeline and Hazardous Materials Safety Administration, in coordination with the Federal Railroad Administration, issued a final rule, entitled “Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains.” In the rule, PHMSA adopted enhanced tank car standards and operational controls for high-hazard flammable trains.  As used in the final rule,  Class 3 refers to the primary hazard or hazard class of the material as indicated in Column (3) of the Hazardous Materials Table in 49 CFR 172.101.

I trust this satisfies your inquiry.  Please feel free to contact me if you need further assistance.


Ben Supko
Senior Regulations Officer
Standards and Rulemaking Division


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table