{"operation":"document","citation":"05-0177","title":"AllTranstek LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-12-13","effective_on":null,"summary":"05-0177 response to AllTranstek LLC concerning 178.345, 179.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0177.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0177.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0177","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050177.pdf","body":"<<<PAGE 1>>>\n\n•\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nPipeline and\nHazardous materials safety\nAdministration\nDEC 1 3 2005\nMr. James H. Rader\nRef. No.: 05-0177\nVice President, Technical Support\nServices\nAllTranstek LLC\n1101 31\" Street, Suite 200\nDowners Grove, IL 60515-5650\nDear Mr. Rader:\nThis is in response to your July 12, 2005 letter concerning the applicability of Part 179 of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to tank cars. Your questions,\nand the answers to them, follow:\nQ1. Does § 179.1(a), (b), and (e) limit the applicability of Part 179 to tank cars \"marked\" only\na \"DOT specification?\nAl. Before responding directly to this question, several precursor elements must be stated. The\n\"marking\" definition in § 171.8 includes a \"specification\" ... \"required by this subchapter.\n\" This definition in the DOT regulations does not include a requirement that the\nspecification be applied to the car in a particular manner. Applicable language in the\nAssociation of American Railroads Tank Car Manual (see Appendix C, 2.0) defines\n\"marking\" and \"stamping\" separately. Both 49 CFR Part 179 and Chapter 3 of the AAR\n\"stamped\" with the as-built specification and other vital information (See §§ 179.100-20\nTank Car Manual require cars to be \"marked\" per Appendix C of the Manual and\nand 179.200-24). It is the \"stamping\" that certifies that the car is built to the specification\nso indicated. Thus, it is reasonable to conclude, as PHMSA and FRA do, that the marking\nrequirements § 179.1(e), insofar as they relate to the tank specification, and the certification\nof compliance to that specification, are directed to the stamping of the specification into the\nhead of the tank car and not to the information applied by decal or paint per Appendix C.\nFurther, the Specifications for AAR Tank Car Tanks set out in Chapter 3 of the Tank Car\nManual, state, for instance, that AAR 203W and AAR 211W cars are built in accordance\nwith a referenced DOT specification except as otherwise provided in that chapter. (See\nChapter 3, paragraph 3.1.1.) Under § 173.31(a) all tank cars used to transport a hazardous\nmaterial must meet the requirements of the specification to which the tank was built.\nGiven the interwoven requirements of the HMR, including Part 179, and the AAR Tank\nCar Manual, it is not possible to say that§ 179.1(a), (b), and (e) limit Part 179 to only those\ncars \"marked,\" i.e., stamped, to a DOT specification. Rather, both the HMR and the Tank\nCar Manual must be read to give the fullest scope and interpretation to each.\n178.345-1\n148.345.14\n050177\n179.1\n\n<<<PAGE 2>>>\n\nQ2. Given the answer in Question (1) above, do the requirements of Part 179 apply to any tank\ncar constructed and marked to an \"AAR\" specification, including the limitations on the\nmaximum gross weight on rail at 263,000 pounds?\nA2. As specified in § 179.1(a) Part 179 prescribes the specifications for tanks that ... are to be\nmarked with a DOT specification. As stated in Al, the crucial marking requirement for\ntank car tanks was the specification stamped into the heads of the tank. Thus, the capacity\nand gross weight limitations established in § 179.13 (See also § 173.26) apply to tank cars\nwhose tanks are head-stamped with a DOT specification. Conversely, \"the weight\nlimitations of § 179.13 do not apply to Class AAR-211W tank cars.\" (See paragraph 3.1.1,\nChapter 3, AAR Tank Car Manual).\nQ3. Do the requirements of Part 179 apply to tank cars constructed to a \"DOT\" specification\nand marked (stenciled) to an \"AAR\" specification? This is similar to the variable\nspecification plate for highway cargo tanks in §§ 178.345-1(j) and 178.345-14(e).\nA3. Because the crucial \"marking\" for the specification of a tank car tank is the head-stamped\nspecification and not an alternative specification painted or decaled on the car, a tank car\ntank stamped with a DOT specification is subject to the requirements of Part 179. There is\nno railroad tank car analogous to the highway cargo tank \"variable specification plate.\"\nI hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely,\nTethe z. Michell\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards.\n\n<<<PAGE 3>>>\n\nPollack\n$179.1\nJames H. Rade\nAALTRANSTEK\n§178.345-1\nVice President Technical Support Service\nAlITranstek L.L.C\nTRANSPORTATION MAMAGEMENT & CONSULTING\n1101 31st Street, Suite 200\n§178.345-14\nDowners Grove, illinois 6051:\n630.829.9125 (office\nMarkine\n630.881.0309 (mobile)\n630.339.0277 (efax)\n15-0114\nJuly 12, 2005\nAssociate Administrator for Hazardous Materials Safety\nRobert A. McGuire\nResearch and Special Programs Administration\n400 Seventh Street, S.W.\nU.S. Department of Transportation\nWashington, D.C. 20590-0001\nAttention: DHM-31\nRe: Request for Interpretation\nDear Mr. McGuire:\n(HMRs) with respect to tank cars marked to an Association of American Railroads specification.\nI am writing to request an interpretation on the applicability of the Hazardous Materials Regulations\nThe HMRs authorize the transportation of hazardous materials, with low to medium hazards, in tanl\nespect to a tank car marked to an \"AAR\" specification, the HMRs require that the tank conform to ihe\npecification to which it was constructed.? Based on these federal requirements, I would like you\ninterpretation with respect to the following:\n1. Does 49 CFR 179.1(a), (b), and (e) limit the applicability of Part 179 to tank cars \"marked\" only to\na \"DOT\" specification?\n2. Given the answer in question (1) above, do the requirements of 49 CFR 179 apply to any tank car\nweight on rail at 263,000 pounds?\nconstructed and marked to an \"AAR\" specification; including the limitations on the maximum gross\n3. Do the requirements of 49 CFR 179 apply to tank cars constructed to a \"DOT\" specification and\nhighway cargo tanks in 49 CFR 178.345-1(j) and 178.345-14(e).\nmarked (stenciled) to an \"AAR\" specification? This is similar to the variable specification plate for\nIf you need any further information, please let me know.\nSincerely,\nJames H. Rader\nVice President Technical Support Services\n' See 49 CFR 173.240, 173.241, and 173.242.\n\" See 49 CFR 173.31(a)(1) and 180.507(a).\n\n<<<PAGE 4>>>\n\nAAR Manual of Standards and Recommended Practices\nM-1002\nSpecifications for Tank Cars\nCHAPTER 3\nCHAPTER 3. SPECIFICATIONS FOR AAR TANK CAR TANKS\nTanks\n3.1 (AAR.100) Specifications Applicable to Class AAR-203W and AAR-211W Tank Car\n3.1.1 (AAR.100-1) General\nDOT-111W specification shown in Table 3.1 (see DOT 179.200 and 179.201) except as provided in\nClass AAR-203W and AAR-211W tanks must be built in accord with the applicable DOT-103W or\nthe following paragraphs. Where AAR paragraph numbers are omitted, the provisions of DOI\n179.200 and 179.201 apply. The weight limitations of 179.13 do not apply to Class AAR-211W tank\ncars.\nTable 3.1 DOT specifications for Class AAR-203W and AAR-211W tanks\nAAR Specification\nApplicable DOT Specification\nAAR-203W\nDOT-103W\nAAR-203DW\nDOT-103DW\nAAR-211A60W1\nDOT-111A60W1\nAAR-211A60ALW1\nDOT-111A60ALW1\nAAR-211A100W1\nDOT-111A 100W1\nAAR-211A100W6\nDOT-111A100W6\nAAR-211A100ALW1\nDOT-111A100ALW1\n3.1.2 (AAR.100-2) Approval\nFor the procedure for securing approval, see paragraph 1.4.\n3.1.3 (AAR.100-4) Insulation\n3.1.3.1 If insulation is applied, insulating material must be approved.\n3.1.3.2 Insulation must be covered with a jacket made of approved material that is applied so as\nto be weather tight.\n3.1.3.3 The exterior surface of a carbon steel tank and the inside surface of a carbon steel jacket\nmust be given a protective coating.\n3.1.4 (AAR.100-10) Welding\nrequirement of this specification.\n3.1.4.1 Radioscopic examination of welded joints of carbon steel or alloy steel tanks is not a\n3.1.4.2 Welded joints of aluminum tanks must be radioscoped in accord with Appendix W.\n3.1.5 (AAR.100-11) Postweld Heat Treatment\nheat treated in accord with Appendix W.\nThe portions of carbon steel tanks to which anchorage or draft sills are attached must be postweld\n3.1.6 (AAR.100-16) Gauging Devices, Top Loading and Unloading Devices, Venting\nDevices, and Air Inlet Devices\ninstalled, protective housing is not required.\nWhen gauging devices, top loading and unloading devices, and venting and air inlet devices are\n3.1.7 (AAR.100-17) Bottom Outlets\nvalves may be of any approved design.\nBottom outlets on AAR specification tanks must conform to DOT-179.200-17 except that external\n12/1/00\nC-III-53\n\n<<<PAGE 5>>>\n\n14216\nRULES AND REGULATIONS\nStato\nCounty\n•Location\nMap No.\nState map repository\nLocal map ropository\narcas which havo\nlectivo dato\nspcolal flood\nontlication\nhazards\nRhodo Island.\nProvidenco.... Providenco.\n- # 11007 0190 07. Ebodo Island, efc.-Coatinued\nDo....\n- Washlogton...\n.. Bouth Kingstora. T 14009020501.........\nSouth Carolina. Charleston.\n- Folly Beach.\nDo.\nTexas.\n.. Harris.\nDo.\nVirginin...\nDo:\nXIII of the Housing and Urban Development\n(Natlonal Flood Insurance Act of 1968 (title\n17804,\nAct of 1968), effective Jan, 28, 1969(33 F.B.\n408-410, Public Lav 91-152, Dec. 24, 1969), 42\nNov.\n28,\n1968),\n8S\namended\n(secs.\nafforded an opportunity to participate in\nthis rule making.\nfleet in order to withstand the rigors of\nof the present tank car\nauthority to Federal Insurance Administra-\nU.S.C.\n4001-4127:\nSecretary's\ndelegation\nof\nlimitation\nRegarding the imposition of a capacity\nof 34,500 gallons,\nmany re-\nthe normal railroad environment over\ntor, 34 F.R. 2680, Feb. 27, 1969; and desig-\nspondents noted that large capacity tank\nupgrading must be accomplished before\nthe expected life of the tank cars. This\nministrator effective July 22, 1970, 35 ER.\nnation\nActing\nFederal\nInsurance\nAd-\ncars tended to reduce the hazard to the\nconsidering allowing increase\nof the\n12360, Aug. 1, 1970)\npublic by reducing the number of cars\nstress loads on equipment and the rail\nIssued: September 8, 1970.\nNo consideration was expressed for the\nrequired for a given volume movement.\nplant caused by heavier cars.\nOne respondent addressed himself to\nActing Federal Insurance\nCHARLES W. WIECKING,\nin a greater hazard in the event that the\nfact that increased capacity will result\nof the tank car and mentioned the ability\nthe influence of weight on kinetic energy\n[FR. Doc, 70-11840; Filed, Sept. 8, 1970;\nAdministrator.\nderailment.\ntank car is punctured or ruptured in a\nLarge capacity\ntank cars\namount of kinetic energy. Increasing the\nof & larger mass to absorb a larger\n8:45 a.m.]\nalso increase\nand air pollution.\nthe hazard of soil, water\nincrease in its kinetic energy at equal\nweight of the tank car produces a linear\nquestion of limiting the total gross weight\nMany responses were addressed to the\nvelocity. This increased kinetic energy in-\nTitle 49—TRANSPORTATION\non rail to 263,000 pounds. Some of the\ncreases the likelihood that the tank will\ndata discussed the validity of a weight\nlimitation as a control measure to im-\nlimiting the maximum weight of a tank\ndent. Therefore, the Board belleves that\nbe punctured or will rupture in an acci-\nChapter I—Hazardous Materials Reg-\nulations\nBoard, Department\non weight-related causative accident fac-\nprove railroad safety, focusing primarily\nrupture.\ncar will reduce incidents of puncture and\n[Docket No. HM-38; Amendment No. 179-4]\nTransportation\ntors and the effects on kinetic energy of\nthe tank car.\ngiven in current design practice to the\nInadequate\nconsideration has been\nPART 179—SPECIFICATIONS FOR\nstress failures in track and car parts ac-\nCausative accident factors show that\nselection of material thicknesses to com-\nTANK CARS\ncount for approximately 50 percent of all\npensate for greater kinetic enerry levels\nRestriction of Capacity of Tank Cars.\nrail accidents. The Board believes that\nAs train operating speeds increase,\nencountered as tank car weight increases.\nthe relationship between such stress fail-\nkinetic energy increases exponentially.\nthis\nThe purpose of this amendment to the\nand Interlocking Couplers\nures and car weight is direct.\nIn every example offered citing rail\nstant despite change in tank car weicht\nSiT design has been held nearly con-\nDepartment of Transportation is to re-\nElazardous Materials Regulations of the\nloads in excess of the proposed limit, par-\nticular mention was made of the special\nvaried only as a function of the tensile\nand capacity, and shell thickness has\nstrict the gross weight and volume ca-\npacity of, and require interlocking cou-\nrouting clearances and controls exercised\nover the movement of these cars. Such\nIt is apparent that the weight (stress)\nstrength of materials and tanks diameter.\nport hazardous materials.\nplers on all new tank cars used to trans-.\nspecial measures are not present in nor-\nmal tank car movement, which is the\nened as a direct function of capacity\nrelated elements have not been strength-\nOn December 11, 1969, the Hazardous\nsituation to which the Board must ad-\nMaterials Regulations Boärd published\ndress itself. Only\none response offered results in a lower factor of safety in\nThe Board believes that this, in elect,\nDocket No. HIM-38; Notice No. 69-31 (34\ndesign data which showed that due con-\nlarger capacity tank cars as related to\nF.R. 19553) proposing to amend Part 179\na tank and running gear to obtain the\nsideration had been given to overbuilding smaller capacity cars.\nof the Hazardous Materials Regulations\nas indicated above. In that notice, the\nmargin\nof safety which is required by the economic impact of the proposed\nVirtually all respondents mentloned\nPoard stated its concern with the in-\ngood engineering practice.\ncreasing number of railroad accidents in-\nWeight related stress\nfailures\nare\nrecognized that the cost of accidents is\nweight-capacity limitations. It must be\nvolving tank cars transporting hazardous\nton\"\nknown to have occurred in existing \"100\nalso a part of the natlonal distributlor\nmaterials in which the tank released its\nweight tank cars which have been in\ncapacity,\n263,000\npounds\ngross\ncosts and is reflected in freight rates\ncontents, through either puncture or rup-\nservice for a period of years. \"Fix\" pro-\neconomic effect of this rule making, the\nIn order to accurately determine the\ning death and personal injury rate re-\nture. Reference was made to the mount-\nrams to correct buckling and fatigue Board retained an independent expert\nracking at both ends of stub sills on to analyze the overall costs of \"large\nFEDERAL REGISTER, VOL. 35, NO. 175—WEDNESDAY, SEPTEMBER 9, 1970\nHeinOnline -- 35 Fed. Reg. 14216 1970\n\n<<<PAGE 6>>>\n\nRULES AND REGULATIONS\n14217\ncapacity\" tank cars as related to \"smaller\ncapacity\" tank cars. The following table\nproliferation of the problems resulting\nsummarzes his findings:\ncapacity tank cars exceeding 34,500 gal-\nrom the continued construction of large\nChapter X-Inferstate Commerce\nSUECHAPTER A-GENERAL RULES AND\nCommission\nSUITARY OF TANE CAB TRANSPOBTATION COSTS\nIons. While the Board recognizes that the\nLIQUEFIED PEIBOLEUM GAS\nCrescent City accident involved tank cars\n[Flith Revised S.O. 1041]\nREGULATIONS\nрет ton\nDollars\nCents per\ncars would have released much greater\nrange, it believes\ngallon\nconsequently increased fire hazard and\nquantities of hazardous materials, with\nPART 1033—CAR SERVICE\nCOD-milo movement:\nimpact forces\nweight on rall would have increased the\nproperty damage. In addition, the added\nDistribution of Boxcars\n70-ton capacity.\n110-ton capacity.\n100-ton capacity.\n1,000-millo moroment:\nton anato\n2. 0151\nL. 6957\nAt a session of the Interstate Com-\n100-ton capacits\n125-ton capacity\n13.52\n1. 7993\nderailment and\nBoard, held in Washington, D.C., on the\n70-ton capacity.\n110-ton capacits-\n10.84\n3.1777\n11. 0S\n2. 7111\nSeveral responses noted the lack of a\nof certain plain boscars exists on the\nIt appearing, That an acute shortage\n100-ton capacity\n110-ton copocity.\nwin capacity\n14.97\n84\n2. 8165\n4. 3103\n\"Iebuilt tank car.\" This term has been\nreadily acceptable definition of the term\nrallroads named in section (a) para-\n16.32\n3.8-7\n3. 7265\ndeleted from the amendment pending the\non the lines of these carriers are being\nraph (1) herein; that shippers located\n3, 5173\nThe Board believes that by requiring\ning, resulting in a severe emergency and\ndeprived of such cars required for load-\nin\nThe table indicates that costs involved\ncar differ little from those costs involved\nutilizing the\n\"100ton\" capacity tank\ninstallation of interlocking couplers that\nwill resist car telescoping and jackknifing\naccept newly harvested. grain, or to store\ncausing grain elevators to be unable to\ncar.\nin utilizing the \"125ton\" capacity tank\nincidence of tank head and side puncture\nin derailments and emérgency stops, the\nnomic loss; that present rules, regula-\ngrain on the ground, thus creating eco-\nactually offers sore cost savings over the\nThe\n\"100ton\" capacity\ntank car\nCity, a tank head puncture caused the\nwill be markedly reduced. At Crescent\ntions, and practices with respect to the\nbelleres public safety warrants the slight\n\"140ton\" capacity tank car.\nThe Board\nuse, supply, control movement, distribu-\nof boxcars owned by these railroads are\ntion, eschange, interchange, and return\nreduction in economic efficiency which\nresults from utilizing \"100ton\" capacity\nfor reasons discussed in the preamble of\nIn consideration of the foregoing and\nineffective. It is the opinion of the Com-\ntank cars.\ntank cars in place of \"125ton\" capacity\nNotice No: 69-31,\n49 CFR Part 179 is\nmission that an emergency exists requir-\nservice in the interest of the public and\ning immediate action to promote car\ncludes that the proposed restrictions on\nFor the above reasons, the Board con-\nand 179.14 are added to read as follows:\nIn the table of contents, $$ 179.13\nthe commerce of the people. Accordingly,\ntank car weight-capacity are in the pub-\nthe Commission finds that notice and\nInvolved in using the \"100ton\" capacity\nlic Interest. Until the present problems\nTank car capacity and gross weight\ncontrary to the public interest, and that\npublic procedure are impracticable and\ntank cars are resolved and until evidence\neffective upon less than 30 days' notice.\ngood cause exists for making this order\nlevels associated with higher unit load-\nis presented to show that increased stress\n(B) $ 179.13 is added to read as\n§ 1033.1041 Service Order No. 1041.\nIt is ordered, That:\nings on the rail plant and tank car equip-\n• adequately compensated for, this will re-\nweight limitation.\nTank car capacity and gross\n(a) Distribution of borcars. Each com-\nmain the Board's conclusion.\n1970, must not exceed 34,500 gallons\nTank cars bullt after November 30,\nInterstate Commerce Act shall observe,\nmon carrier by rallroad subject to the\nThe Board further believes that the\ncouplers on all new tank cars will mate-\nof interlocking\ncapacity or 263,000 pounds gross weight\nExisting tank cars may not be\nits car service:\nregulations, and practices with respect to\nincidence of tank head puncture\npacity or 263,000 pounds gross weight on\nas otherwise authorized in subparagraph\n(1) Return to owners empty, except\nthere have been 19 accidents involving\nSince the date of Notice No. 69-31,\n(C) $ 179.14 is added to read as\nwhich are listed in the Official Railway\n(2) of this paragraph, all plain boxcars\ntank cars transporting hazardous mate-\nEquipment Register, I.C.C. R.E.R.\nreleased causing severe hazard. One such\nrials in which the contents have been\nAll tank cars built after November 30,\nTank car couplers.\nthereof, as having mechanical designa-\naccident occurred at Crescent City, Ill.,\n1970, must be equipped with interlocking\nand equipped with doors less than 9 feet\ntion XM, with inside length 44'6\" or less\nwide, owned by the following rallroads:\nFederal find diministration.\nFEDERAL REGISTER, VOL. 35, NO. 175—WEDNESDAY, SEPTEMBER 9, 1970\nHeinOnline -- 35 Fed. Reg. 14217 1970\n\n<<<PAGE 7>>>\n\nPage 1 of 2\nPollack, Arthur <PHMSA>\nFrom:\nPhemister, Tom <FRA>\nSent:\nMonday, December 12, 2005 12:15 PM\nTo:\nPollack, Arthur <PHMSA>\nCc:\nSchoonover, William <FRA›; Mitchell, Hattie < PHMSA>\nSubject: RE: Interpretive request by James Rader\nArthur:\nJust as a reminder, l'd appreciate a pdf of the signed letter so we can easily respond to similar interpretive requests.\nIf anyone above you and me on the food chain makes substantive changes, please call or write. Thanks.\nTom\n-----Original Message-.-..\nSent: Monday, December 12, 2005 8:31 AM\nFrom: Pollack, Arthur <PHMSA>\nCc: Schoonover, William; Mitchell, Hattie <PHMSA>\nTo: Phemister, Tom\nSubject: RE: Interpretive request by James Rader\nTom-Thank you for your input and help on the Jim Rader letter. Attached is the latest version we have put on\nminor format edits) per your request.\ngrid. We have made no substantive changes to your input but are sending you this updated version (with\n-Arthur\n-----Original Message---\nFrom: Phemister, Tom <FRA>\nSent: Wednesday, December 07, 2005 9:58 PM\nCc: Schoonover, William <FRA›; Mitchell, Hattie <PHMSA>\nTo: Pollack, Arthur <PHMSA>\nSubject: Interpretive request by James Rader\nOn November 8, you sent me a draft letter in response to an inquiry by James Rader of AllTranstek\nabout marking tank cars. Thank you for the opportunity to comment.\nI am attaching an alternative text with which FRA concurs; because of the sensitive nature of this\nattached text. The alternative text is attached in both Word and WordPerfect formats.\nsubject (more later) FRA requests the opportunity to see and agree to any modifications made to the\nMr. Rader raises a very interesting set of questions and because both FRA's Staff Director, Hazardous\nMaterials, and I have known the author for many years, we understand that the issue beneath the\nissue that he formally raises is really the key. Mr. Rader talked about \"marking\" lank cars and phrased\nthe head stamping required by 179.100-20 and 179-200-24 (non-pressure and pressure cars,\nhis questions that way. The crucial missing step in his questions, but one which DOT must address, is\nspecification stamped on the tank head establishes the specification to which the car was built. Cars\nrespectively). It is clearly understood in the tank car industry, and FRA has so enforced, that the\n12/12/2005\n\n<<<PAGE 8>>>\n\nPage 2 of 2\nthey are still, at base, DOT cars. Car owners and shippers often make the change in order to take\nmay be built as \"DOT-specification\" cars and stenciled on the side with an \"AAR-specification,\" but\nreasons of perceived economic necessity. What they cannot do by merely painting a different\nadvantage of AAR's somewhat less stringent requirements for service equipment (valves) and for other\nwithout a Special Approval. DOT and AAR requirements on this point are quite different: 173.26 limits\nspecification on the car is circumvent the quantity and weight restrictions in 173.26 - at least not\nAAR Tank Car Manual specifically states that \"the weight limitations of 179.13 do not apply to Class\n(via 179.13) the capacity and gross weight of DOT-specification cars while Chapter 3 (at 3.1.1) of the\nAAR 211W tank cars.\"\nSubpart F. We cannot, as stewards of the railroad hazardous materials safety program for DOT, allow\nFRA's continuing qualification requirements for DOT-specification cars form the basis for Part 180,\nqualification requirements at the heart of Part 180, Subpart F and a primary purpose of the requirement\ndrastically heavier cars to operate without extra oversight - that is a primary purpose of the re-\nprocess has enabled FRA to require structural and equipment betterments beyond the bare minimums\nthat DOT tank cars operated above the limits of 179.13 receive a Special Permit. The Special Permit\ntank car fleet.\nof the DOT-specification and that, in turn has contributed to the excellent safety record of the current\nfor tank cars contained in Part 179. They have, and with the continued efforts of FRA and PHMSA, will\nAgain, I appreciate this opportunity to apprise the industry of the sovereignty of the DOT-specifications\nrailroad\ncontinue to represent the state-of-the-art in bulk packaging for moving hazardous materials by\nPlease call if you have any questions.\nTom Phemister\n202 493 6050\n12/12/2005","truncated":false,"body_characters":24160}