{"operation":"document","citation":"16-0176","title":"SGS Petroleum Service Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-04-05","effective_on":null,"summary":"16-0176 response to SGS Petroleum Service Corporation concerning 179.200, 179.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0176.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0176.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0176","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/160176.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nAPR 0 5 .2017\nMr. Glenn Gillaspia\nCompliance Manager\nSGS Petroleum Service Corporation\n5055 Preston Avenue\nPasadena, TX 77505\nReference No. 16-0176\nDear Mr. Gillaspia:\nThis letter is in response to your October 20, 2016, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to securement of rail\ntank car closures. Specifically, you ask whether chains are required on caps or plugs used to\nsecure openings on product and vapor valves located inside the top housing on DOT\nSpecification 111 tank cars.\nThe answer depends on the design as it was approved by the Association of American Railroads\n(AAR) Tank Car Committee. As prescribed in§ l 79.200-l 7(a)(l), bottom outlet reducers,\nclosures, and their attachments are required to be secured to the car by 3/8-inch or 1/4-inch chain\nunder certain conditions. The HMR do not contain a similar provision for top fittings, such as\nliquid and vapor valves on DOT Specification 111 tank cars. However,§§ 179.3 and 179.200-16\nrequire the tank car design and top loading and unloading devices to be approved by the AAR\nTank Car Committee. Thus, a chain is required on a liquid or vapor line closure, such as a pipe\nplug, if the tank car design as approved by the AAR Tank Car Committee includes a chain\nattached to the closure.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\n~~\n~ (7~, 2__00\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\n~cvJ\nRivera, Jordan CTR (PHMSA)\nWednesday, October 26, 2016 9:22 AM\nHazmat Interps\nFW: Interpretation Request\nHi Shante/Alice,\nPlease submit this as a letter of interpretation. I have been unable to get in contact with Mr. Gillaspia.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: Gillaspia, Glenn (Pasadena) [ rnc;iilto:Gleno~Gillc;isQiali:i~~gs.cQm ]\nSent: Thursday, October 20, 2016 1:52 PM\nTo: PHMSA HM lnfoCenter\nSubject: Interpretation Request\nI would like some clarification on the following concerning general purpose DOT 111 rail cars. I have been\ntold two different interpretations. Are chains required to be attached to the liquid and vaper caps/ plugs,\nunder the housing cover, on the top of the DOT 111 rail cars?\nThank you for any clarification\nGlenn\nGlenn Gillaspia\nCompliance Manager\nSGS Petroleum Service Corporation\n5055 Preston Ave.\nPasadena, TX. 77505\nPhone: 281-991-3500\nMobile: 713-924-8051\nInformation in this email and any attachments is confidential and intended solely for the use of the individual(s)\nto whom it is addressed or otherwise directed. Please note that any views or opinions presented in this email are\nsolely those of the author and do not necessarily represent those of the Company. Finally, the recipient should\ncheck this email and any attachments for the presence of viruses. The Company accepts no liability for any\ndamage caused by any virus transmitted by this email. All SGS services are rendered in accordance with the\n1\n\n<<<PAGE 3>>>\n\napplicable SGS conditions of service available on request and accessible at http://www.sgs.corn/en/Terrns-\n~ind-Conditions. aspx\n2","truncated":false,"body_characters":3387}