Mr. Patrick F. Reilly — Hazardous Materials Safety Interpretation

Page 1.S. Departmer f Transportatio 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administratior JUL 27 2006 919 Parkview Road Mr. Patrick F. Reilly Ref. No. 06-0147 Moscow, PA 18444 Dear Mr. Reilly: This responds to your June 29, 2006 letter requesting clarification on § 171.7 Reference material, materials incorporated by reference into the Hazardous Materials Regulations (HMR; 49 CFR 171-180). Specifically, you ask whether the "Association of American Railroads, AAR Manual of Standards and Recommended Practices, Section C-Part III, in § 171.7 is the most current version. Specification for Tank Cars, Specification M-1002, December 2000 edition" referenced The AAR standard you reference was updated as of December 1, 2003. However, the updated standard has not been incorporated by reference into the HMR. Therefore, for purposes of the HMR, the 2000 edition referenced in § 171.7 must be used. I hope this answers your inquiry. Sincerely, MESA Chief, Standards Development Office of Hazardous Material Standards 171.7 060147#

Page 210 Boothe PATRICK F. REILLY 171.7 Reference Material 06-0147 6/29/06 Mr. Robert McGuire Associate Administrator U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 400 7th Street S. W. Washington, D.C. 20509 I have a question concerning the hazardous materials regulations and was directed to your Dear Mr. McGuire: office. I was informed you are the lead DOT agency for writing and maintaining the DOT regulations for the transportation of Hazardous Materials. In review of 49 CFR 171.7, a regulation that incorporated by references several technical ublications. One of those publications so noted in this sections is the Association of American Railroads, AAR Manual of Standards and Recommended Practices, Section C Part III, Specifications for Tank Cars, Specification M-1002, December 2000 edition. The Current edition of this publication was updated in 2003. Contained in the 2003 edition on page C-III-3, section 1.1.1, it states that this issue of the AAR Specification for Tank Cars dated October 1, 2003, supersedes the issue dated December 1, 2000. Yesterday, Wednesday, June 28, 2006, I called the Federal Railroad Administration and that this was an oversight in updating the current CFR. My question is. Is this correct, spoke to Mr. Ray Casey who is a Hazardous Material Specialist. Mr. Casey informed me regulation and not an outdated version? and can I assume that the current AAR Specifications for Tank Cars is referenced in the Thank you in advance for your assistance, looking forward to your response. Sincerely PF. Reilly#