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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #22-0087

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

Interpretation Response Details

Response Publish Date:

Company Name: Olin Corporation

Individual Name: Daniel T. Stein

Location State: TN Country: US

View the Interpretation Document

Response text:

March 28, 2024

Mr. Daniel T. Stein
Fleet Equipment Lead
Olin Corporation
490 Stuart Road, NE
Cleveland, TN  37312-4918

Reference No. 22-0087

Dear Mr. Stein:

This letter is in response to your August 19, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to ownership of equipment when performing repairs, alterations, conversion, and modifications of rail tank cars and service equipment.

We have paraphrased and answered your questions as follows:

Q1. You ask whether the intent of § 180.513(b)—Responsibilities of Tank Car Facility—pertains to obtaining the permission of an equipment owner in a scenario where there are multiple owners of the assets (e.g., tank cars, liners, or service equipment).

A1. Under § 180.513(b), "A tank car facility must obtain the permission of the equipment owner before performing work affecting alteration, conversion, repair, or qualification of the owner's equipment." If the tank car and/or the tank car service equipment have multiple owners, the tank car facility would need permission from all owners of said asset, or the owner of the affected equipment.

Q2. You ask whether the service equipment owner or the tank car owner is responsible for establishing the interval for service equipment inspection and testing.

A2. Under § 180.509(k)(1), "Each tank car owner must ensure the qualification of tank car service equipment at least once every ten (10) years." As this is a minimum requirement, any service equipment inspection and test interval that is less than 10 years is allowed and may be initiated by the service equipment owner or the tank car owner. If either party—the service equipment owner or the tank car owner—is aware of inspection.

and test results that indicate that the design level of reliability and safety of the service equipment will not be met for a given inspection and test frequency, this information must be shared between the parties involved and an appropriate inspection and test frequency selected.

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


Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

180.513(b), 180.509(k)(1)

Regulation Sections

Section Subject
180.509 Requirements for inspection and test of specification tank cars
180.513 Repairs, alterations, conversions, and modifications