Interpretation Response #99-0066 ([Transportation Safety Degussa Corporation] [Mr. John Foglio])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Transportation Safety Degussa Corporation
Individual Name: Mr. John Foglio
Location State: NJ Country: US
View the Interpretation Document
Response text:
AUG 25, 2000
Mr. John Foglio Ref. No. 99-0066
Manager, Hazardous Materials
Transportation Safety Degussa Corporation
65 Challenger Road
Ridgefield Park, NJ 07660
Dear Mr. Foglio:
I apologize for the delay in responding to your letters concerning the requirement in 49 CFR 173.31 (d)(1 )(vi) to carefully inspect a frangible (rupture) disc in a pressure relief device prior to each hazardous material shipment. This requirement has its origins in regulations of the Interstate Commerce Commission issued in 1921. Its wording was most recently revised in a final rule published on September 21, 1995, under RSPA's DocketNos.HM-175A and 201 (60 Fed. Reg. 49098).
As the language of § 173.31 (d)(1 )(vi) states, the purpose of this type of inspection is to check "for corrosion or damage that may alter the intended operation of the device." For that reason, in response to a comment submitted in a separate rulemaking proceeding under Docket No. HM-216 (61 Fed. Reg. 28666, 28671; June 5, 1996), we stated in the preamble that RSPA and FRA believe in order to fully inspect a rupture disc (both top and bottom), the disc must be removed from the safety vent device. It has been FRA's experience that a rupture disc may appear normal on the top side, but be severely damaged or corroded on the bottom side.
You and others have raised concerns about the language of the present rule and its application to persons that forward a loaded tank car received from another location or return a tank car with residue. We anticipate initiating a rulemaking in the near future to address these concerns.
Sincerely,
Edward T. Mazzullo
Director, Office of Hazardous Materials Standards
173.31
Regulation Sections
| Section | Subject |
|---|---|
| 173.31 | Use of tank cars |