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

摘要

The incoming letter is from an association. Apparently one of the questioner's members receives rail shipments of methanol, empties the rail tank cars at their site, closes the valves and has a railroad return the residue rail cars back for refilling. He asks whether closing a rail tank car valve upon emptying constitutes "securing a closure" as used in the pre-transportation function described in 171.1 (b)(4) or whether it is sealing the package to prevent tampering which in the mind of the questioner is not a pre-transportation function. PHMSA responds by saying they consider the closing of the valve as constituting "securing a closure."