STARS Operations Manager, Joseph Connelly, recently contacted PHMSA requesting clarification on the proper tank car loading and unloading procedures during the required external visual inspection of piping, valves, fittings, and gaskets listed in 49 CFR 173.31(d)(1)(ii). Specifically, loaders have been unsure if they are required to remove the bottom outlet valve or open the manway cover to assess the condition of the gasket, and whether or not they are permitted to leave the opening closed and just observe for leakage. PHMSA responded with the following clarification.
PHMSA Interpretation 15-0031
