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HM-251/FAST Act Timeline
The Railway Supply Institute (RSI) joins a newly created task force made up of industry stakeholders to review and develop recommendations for a new enhanced Class-111 tank car for tank cars in ethanol and petroleum crude oil service.
The Association of American Railroads (AAR), along with the railway supply industry, formally petitions the Pipeline and Hazardous Materials Safety Administration (PHMSA) to amend the hazardous materials regulations to require the use of an enhanced Class-111 tank car to transport ethanol and petroleum crude oil. The industry’s designation for the new tank car standard is an “enhanced Class-111 tank car,” or a “CPC-1232 tank car,” based on the AAR circular letter number, “CPC-1232.” [Read Petition]
RSI meets with Secretary Anthony Foxx, Department of Transportation (DOT), Cynthia Quarterman, PHMSA Administrator, and Joseph Szabo, Federal Railroad Association (FRA) Administrator, to present a comprehensive set of recommended standards for new tank cars and recommended retrofits for existing tank cars. RSI met with federal regulators again in March 2014. [View Document]
The U.S. Department of Transportation (DOT) released a Notice of Proposed Rulemaking (NPRM) to improve the safe transportation of flammable liquids, including ethanol and petroleum crude oil, in railroad tank cars. RSI-CTC released a statement on the RSI’s Committee on Tank Car’s commitment to safety and a review of the NPRM. [View Document]
The U.S. Department of Transportation (DOT) released a long-awaited final regulation to reduce the risk of transportation of flammable liquids, including ethanol and petroleum crude oil in railroad tank cars. RSI-CTC released a statement in response. [View DOT Regulation]
The FAST Act included all major recommendations advocated by RSI-CTC, and those recommendations clarified PHMSA’s Docket HM-251 implementing regulations that would help reduce the risk of transporting flammable liquids in railroad tank cars. The law set deadlines for the aggressive and appropriate phase-out of Class-111 tank cars transporting a flammable liquid. [View RSI press release on the FAST Act]
More than 18 months ahead of the FAST Act deadline, the industry reported that it had removed 97 percent of Class-111 cars from petroleum crude oil service. [See our update on the implementation of the FAST Act]
On July 13, 2016, Marc Garneau, Minister of Transport, Transport Canada, issued Protective Direction 38 which further accelerated the phase out of Class-111 tank cars. As a result of the directive, no person in Canada could offer for transport, handle, or transport petroleum crude oil in either a jacketed or non-jacketed Class-111 tank car in Canada after November 1, 2016.
The industry obtained full compliance with Transport Canada’s Protective Direction 38, which required the removal of Class-111 tank cars from petroleum crude oil service in Canada by November 1, 2016. [Read Protective Direction here]
In the U.S. as required by the FAST Act, all non-jacketed Class-111 transporting petroleum crude oil were phased out of service . The industry met 97 percent of this goal 18-months ahead of schedule.
As required by the FAST Act, all jacketed Class-111 tank cars were no longer in crude oil service.
Transport Canada issues Protective Direction 39 to further accelerate the phase out of non-jacketed enhanced Class-111 tank cars in crude oil service to November 1, 2018, and non-jacketed enhanced Class-111 tank cars in condensate service to January 1, 2019. [Read Protective Direction here]
As required by the FAST Act, all non-jacketed Class-111 built to the enhanced standard are to be phased out of petroleum crude oil service.
As required by the FAST Act, all legacy jacketed and non-jacketed Class-111 are to be phased out of ethanol service.
As required by the FAST Act, all non-jacketed Class-111 built to the industry’s enhanced standard are to be phased out of ethanol service.
Phase-Out of Class 111 Tank Cars for Crude Oil, Ethanol, and Other Flammable Liquids in Packing Group 1
As required by the FAST Act, Class 111 tank cars are no longer authorized for ethanol, petroleum crude oil, and other flammable liquids in Packing Group 1.
As required by the FAST Act, all Class-111 tank cars, including those built to the enhanced standard, are prohibited in transporting a flammable liquid.
Toxic Inhalation Hazards Timeline
FRA is required to validate modeling of forces in accidents and implement appropriate design standards for pressurized tanks.
Dow Chemical, Union Pacific Railroad and Union Tank Car formed a project team to research strategies to improve tank car accidents performance by a factor of 5 to 10 times the then-current baseline cars.
FRA sponsored two full-scale impact tests during 2007.
CPC-1187 Implementation of the AAR Standard for Tank Cars Transporting Toxic Inhalation Hazard (TIH) Commodities
The CPC-1187 circular issues by AAR required more robust tank specifications for anhydrous ammonia, chlorine and other TIH products. New car specifications included 9 mph rollover protection and a 10-year phase out of the legacy TIH Fleet. CPC-1187
This industry petition from the American Chemistry Council (ACC), the American Short Line and Regional Railroad Association (ASLRRA), the Association of American Railroads (AAR), the Chlorine Institute (CI), and Railway Supply Institute (RSI) requested that the DOT consider interim TIH standards based on improved CPR (Conditional Probability of Release) measurements.
Research on modeling forces in derailments and understanding of the performance of various design elements revealed that current designs involving multiple layers of steel performed best against smaller impactors. Additional research would continue under the Advanced Tank Car Collaborative Research Program (ATCCRP).
Authorized the use of interim tank specifications for new construction of TIH cars DOT-105J500I, DOT-112J500I or DOT-105J600I, depending on commodity, and 9 mph rollover protection. These cars are limited to a 20-year regulatory life.
The Advanced Tank Car Collaborative Research Program (ATCCRP) was initiated to coordinate research efforts to enhance the safety and security of rail tank car shipments of toxic inhalation hazard (TIH) materials. [Read more about the full background of the ATCCRP]
Immediately following the ATCCRP Petition for a Final TIH Specification, the AAR petitioned PHMSA for a 6-year phase out of the legacy TIH Fleet. [Read the petition]
Based on the ATCCRP research conclusions, industry stakeholders (including the RSI) petitioned PHMSA to make the interim standard (HM-246) a permanent standard for TIH service. [Read the petition]
The AAR issued revisions to the TIH standard that required all tank cars in TIH service to meet HM-246 requirements by July 1, 2023. Tanks made from non-normalized steels must be removed from TIH service by July 1, 2029. [Read CPC-1325]
PHMSA accepted ATCCRP petition for adoption of the HM-246 interim TIH tank cars as the final TIH standard. The attached response was sent to the AAR.