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Interpretation Response #22-0082

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

Interpretation Response Details

Response Publish Date:

Company Name: TMC Engineering Services Inc.

Individual Name: R.G. Ashton

Location State: TX Country: US

View the Interpretation Document

Response text:

September 23, 2022

R.G. Ashton
Director of Quality Assurance and Regulatory Compliance
TMC Engineering Services Inc.
2335 Wadsworth Street
Houston, TX  77015

Reference No. 22-0082

Dear Mr. Ashton:

This letter is in response to your August 15, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to tank car facility procedures and recordkeeping. You describe a scenario in which certain documents (e.g., quality assurance program policies and procedures, AAR approvals, tank car owner's acceptance criteria, engineering drawings, etc.) are maintained in an electronic database at the tank car facility. Furthermore, you state that the electronic database is easily accessible to employees at designated computers throughout the tank car facility. You ask whether these documents—which are maintained in the specified electronic database format—meet the requirements of § 179.7(b)(5) and (d).

The answer is yes. Although the provisions in § 179.7 refer to written procedures, they are not so restrictive that the procedures must be provided in paper form—rather the reference to written procedures is to ensure a permanent record for use of the procedures. A tank car facility may maintain the documents required by § 179.7 in an electronic or paper format. Please note that whichever format is implemented, the tank car facility is responsible for ensuring that the documents are both stored properly and accessible for use by employees—ensuring work on the tank car conforms to the specification, AAR approval, and owner's acceptance criteria.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

179.7, 179.7(b)(5) and (d)

Regulation Sections

Section Subject
179.7 Quality assurance program