INDSPEC Chemical Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department Washington, D.C. 20590 1200 New Jersey Avenue, SE of Transportation Pipeline and Hazardous Materials Safety Administration APR 2 1 2010 Ms. Vicki H. Weightman Manager, Technical Services and Regulatory Affairs INDSPEC Chemical Corporation 1010 William Pitt Way Pittsburgh, PA 15238 Ref. No. 09-0209 Dear Ms. Weightman: This responds to your September 2, 2009 letter requesting clarification of requirements for loading tank cars with hazardous materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the tank car loading operation must be attended. Section 173.31 provides general requirements for transporting hazardous materials in tank cars, including tank car loading and unloading requirements. Additional requirements for loading and handling tank cars are in § 174.55. Section 174.67 establishes requirements for transloading tank cars that is, for transferring hazardous materials from one tank car to another tank car or from a tank car to a cargo tank motor vehicle or vice versa. Transloading operations must be attended in accordance with § 174.67(i); however, the HMR do not include specific requirements for attending rail tank car loading operations. We have initiated a rulemaking to consider whether additional measures are necessary to reduce the risks associated with loading and unloading ofbulk packagings containing hazardous materials, including rail tank cars. We plan to publish a notice ofproposed rulemaking in 2010. I hope this answers your inquiry. If you need further assistance, do not hesitate to contact our office. Sincerely, '01t~ Charles E. Betts Chief, Standards Development o Ice of Hazardous Materials Standards#

Page 2axy INDSPEC Chemical Corporation 1010 William Pitt Way, Pittsburgh, Pennsylvania 15238 ~ ~ 1\ subsidiary of Occidental Petroleum Corporation Phone 412.826.3666 Fax 412.826.3699 www.indspec-chem.com ~oo+he. September 2, 2009 S 11 t-J . (p7 (;) ~ 177·834 6) Loa r1 (~~ c:r Un ltXl.dI n j 09"02 0 1 Mr. Edward T. Mazzullo Director, Office of Hazardous Material Standards US DOT/PHMSA (PHH-10) 1200 New Jersey Avenue, SE East Building, 2nd Floor Washington, DC 20590 Dear Mr. Mazzullo, INDSPEC Chemical Corporation respectfully requests your assistance in the identification of the attendance requirements for the loading of tank cars with hazardous materials in the Code of Federal Regulations. The requirements for the tank car unloading can be found in 49CFR 174.67(i). Likewise loading and unloading attendance requirements for tank trucks can be found in 49CFR 177.834(i). Your assistance is appreciated. I can be reached at 412-826-3669 with any questions. Could you also look into an earlier request with regard to Specification Packaging as I have not received a response. The original request is enclosed. Sincerely, '-' INDfPEC c~emic~c~rp~ration (//tikYlI()&t:tr/ca~ Vicki H. Weightman () ~ Manager, Technical Services and Regulatory Affairs VHW/pb Enclosure#