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

摘要

Here is an interpretation letter that I discussed previously (see the March/April 2016 edition) but on which additional interesting issues have been raised. The original questioner asked whether the tank car bottom outlet valve caps must be removed and manway covers opened when an external visual inspection is conducted in accordance with § 173.31(d)(l)(ii). It calls for a person offering a rail tank car with hazmat to, as a minimum, perform an external visual inspection that includes: "The piping, valves, fittings, and gaskets for corrosion, damage, or any other condition that makes the tank car unsafe for transportation."