The Journal of HazMat Transportation's™ Exclusive Comments on Current U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations

摘要

The questioner,in question 1,asks whether a DOT-111 tank car manufactured after October 1,2015 may be converted to a DOT117R.The questioner would like PHMSA to say “no” and PHMSA responds agreeing with the recommended response.The answer is important in that rail tank cars are costly so that for some this is not a trivial issue.What do the regulations actually say?