Interpretation Response #19-0040
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Greenbrier Management Services
Individual Name: James Rader
Location State: OR Country: US
View the Interpretation Document
Response text:
September 16, 2019
James H. Rader
Greenbrier Management Services
1 Centerpointe Drive
Suite 200
Lake Oswego, Oregon 97035
Reference No. 19-0040
Dear Mr. Rader:
This letter is in response to your March 13, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the phase-out of Department of Transportation (DOT) Specification 111 (DOT-111) tank cars. Specifically, you ask whether DOT-111 tank cars may continue in combustible liquids service after the phase-out period in the United States.
The answer is yes. As you correctly point out in your email, the May 8, 2015 final rule states that "Existing HMR requirements for combustible liquids will not change as a result of this final rule." [80 FR 26676]. Therefore, a material classed or reclassed as a combustible liquid may continue to be transported in DOT-111 tank cars beyond the specified phase-out dates in the United States.
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
Standards and Rulemaking Division