Interpretation Response #17-0029 ([Thatcher Transportation, Inc.] [Mr. Brent Olsen])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Thatcher Transportation, Inc.
Individual Name: Mr. Brent Olsen
Location State: UT Country: US
View the Interpretation Document
Response text:
May 22, 2017
Mr. Brent Olsen
Safety Manager
Thatcher Transportation, Inc.
1905 Fortune Road
Salt Lake City, UT 84104
Reference No. 17-0029
Dear Mr. Olsen:
This letter is in response to your March 21, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the emergency shutoff marking on cargo tanks. You note that § 172.328(d) specifies the emergency shutoff marking must be immediately adjacent to the emergency closure device. You state that you received a violation for the emergency shutoff marking not being close enough to the emergency closure device and include in your email a photo showing the marking approximately 4 inches right of and 12 inches above the device. Specifically, you ask how close the emergency shutoff marking must be to the emergency closure device in order to meet the requirements of § 172.328(d).
Section 172.328(d) does not specify the distance the emergency shutoff marking must be in order to be immediately adjacent to the emergency closure device. However, based on the description you provided in your email and the attached photo, it is the opinion of this Office that the emergency shutoff marking, as pictured, would be considered adjacent to the emergency closure device.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.328(d)
Regulation Sections
| Section | Subject |
|---|---|
| 172.328 | Cargo tanks |