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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 #22-0134

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

Interpretation Response Details

Response Publish Date:

Company Name: SMBC Rail Services LLC

Individual Name: Dan Welch

Location State: IL Country: US

View the Interpretation Document

Response text:

March 2, 2023

Dan Welch
Vice President – Sourcing & Regulatory Compliance
SMBC Rail Services LLC
300 South Riverside Plaza
Suite 1925
Chicago, IL  60606

Reference No. 22-0134

Dear Mr. Welch:

This letter is in response to your December 12, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to tank car lining qualification. Specifically, you ask whether an owner of the internal coating or lining of a tank car must receive approval from the Federal Railroad Administration (FRA) Associate Administrator for Railroad Safety in order to qualify tank car internal coatings or linings with an interval of more than eight (8) years between qualification events.

The answer is yes. In accordance with § 180.509(i)(2), the owner of the tank car internal coating or lining must use its knowledge of the service life of each coating or lining and commodity combination to establish an appropriate inspection interval for that coating or lining and commodity combination. This interval may only exceed eight (8) years if the coating or lining owner can establish, document, and show that the service history or scientific analysis of the coating or lining and commodity pairing supports a longer inspection interval. The authorization in § 180.509(i)(2) to exceed an 8-year qualification interval is an alternate inspection and test procedure than what is specified by rule in § 180.509; therefore, subject to § 180.509(l) and approval by the Associate Administrator for Railroad Safety, FRA.

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


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

180.509(l), 180.509(i)(2)

Regulation Sections

Section Subject
180.509 Requirements for inspection and test of specification tank cars