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HM-251/FAST Act Timeline
Railway Supply Institute Joins Task Force
The railway supply industry joins a newly created task force made up of industry stakeholders to review and develop recommendations for new tank car standards for tank cars in ethanol and crude oil service.
“Good Faith” Petition to PHMSA
The Association of American Railroads (AAR), along with the railway supply industry, formally petitions the Pipeline and Hazardous Materials Safety Administration (PHMSA) to codify a new standard based on changes developed by the tank car task force. This standard is known as “CPC-1232” or “Good Faith” car. [Read Petition]
While the PHMSA petition is pending, the railway supply industry voluntarily implements the “CPC-1232” standard for newly ordered tank cars for crude and ethanol in packing groups I and II, which incorporates changes developed by the tank car task force. [View CPC-1232 Standard]
ANPRM for HM-251
PHMSA publishes an Advanced Notice of Proposed Rulemaking (ANPRM) for docket HM-251, regarding regulatory revisions to improve the transportation of hazardous materials by rail. [View Document]
Comments on ANPRM for HM-251
The Railway Supply Institute (RSI) submits comments to PHMSA on ANPRM for HM-251, laying out its recommendations for improving the regulations applicable to transportation of hazardous materials by rail, including recommendations regarding new and existing tank car standards. [View Document]
RSI Meets with DOT
RSI meets with U.S. Department of Transportation (DOT) Secretary Anthony Foxx, PHMSA Administrator Cynthia Quarterman and Federal Railroad Association (FRA) Administrator Joseph Szabo to present a comprehensive set of recommended standards for new tank cars and recommended modifications for existing tank cars. RSI met with federal regulators again in March. [View Document]
PHMSA Testifies on Need for Prevention
PHMSA Administrator Cynthia Quarterman states at a Senate hearing on rail safety that a comprehensive approach is required and that regulators “need to first concentrate on prevention” of train derailments. [View Hearing]
RSI Meets with Transport Canada
RSI meets with Canadian Minister of Transport Lisa Raitt to present its recommendations on changes to tank car standards and to encourage harmony between future U.S. and Canadian regulations. [View Follow-Up Letter]
RSICTC Meets With OMB
RSICTC meets with the White House Office of Management and Budget (OMB) regarding the impact of new tank car standards, tank car production and modification capacity considerations, and RSICTC’s recommendation proposal to PHMSA. [View Outline]
RSICTC Reacts to USDOT’s NPRM
The U.S. Department of Transportation released a Notice of Proposed Rulemaking (NPRM) to improve the safe transportation of flammable liquids, including crude oil and ethanol, by rail. RSICTC released a statement on Committee on Tank Car’s commitment to safety and review of the NPRM. [View Document]
RSICTC Press Release Final Rule – Crude by Rail Regulation
The U.S. Department of Transportation released a long-awaited final regulation to reduce the risk of transportation of flammable liquids, including crude oil and ethanol, by rail. RSICTC released a statement in response. [View DOT Regulation]
FAST Act Signed into Law
The FAST Act included all major recommendations that had been advocated for by the RSICTC and clarified the U.S. DOT HM-251 regulations to reduce the risk of transport of flammable liquids by tank car. The law set deadlines for the aggressive and appropriate transition from the DOT-111 to the DOT-117 standard. [View RSI press release on the FAST Act]
97 Percent of DOT-111 Removed from Crude Oil Service
More than 18 months ahead of the FAST Act deadline, the industry reported that 97 percent of DOT-111 cars had been removed from crude oil service. [See our update on the implementation of the FAST Act]
Canada’s Minister of Transport Accelerates DOT-111 Phase-Out Schedule
The Minister of Transport Canada, Marc Garneau, issued Protective Direction 38 on July 13, 2016, which further accelerated the phase out of DOT-111. As a result of the directive, both jacketed and non-jacketed DOT-111 tank cars were prohibited from carrying crude oil in Canada after November 1, 2016.
DOT-111 Removed From Crude Oil Service in Canada
The industry was in full compliance with Transport Canada’s Protective Direction 38, which required all DOT-111 tank cars to be removed from crude oil service in Canada. [Read Protective Direction here]
First FAST Act Deadline
All non-jacketed DOT-111 carrying crude oil have been phased out of service in the U.S., as required by the FAST Act. The industry met 97 percent of this goal 18-months ahead of schedule.
Jacketed DOT-111 Deadline for Crude Oil Tank Cars
All jacketed DOT-111 have been removed from crude oil service, as required by the FAST Act.
Canada Accelerates Phase Out Timeline
Transport Canada issue Protective Direction 39, to further accelerate the phase out timeline for unjacketed CPC-1232 tank cars in crude oil service to November 1, 2018, and DOT-111 and unjacketed CPC-1232 tank cars in condensate service to January 1, 2019. [Read Protective Direction here]
DOT Removed ECP Brake Requirements
DOT removes ECP brake requirements for High Hazard Flammable Liquids Unit Trains. [Read Federal Register Notice here]
Deadline for Non-Jacketed CPC-1232 in Crude Oil
All non-jacketed DOT-111, built to the industry’s voluntary CPC-1232 standard, are to be phased out of crude oil service, as required by the FAST Act.
DOT-111 Phased Out of Ethanol Service
All jacketed and non-jacketed DOT-111 carrying ethanol are to be phased out of service, as required by the FAST Act.
Non-Jacketed CPC-1232 Phased Out of Ethanol Service
All non-jacketed DOT-111 built to the industry’s voluntary CPC-1232 standard are to be phased out of ethanol service, as required by the FAST Act.
DOT-117 Required for Crude Oil, Ethanol and Other Flammable Liquids in Packing Group 1
DOT-117 or equivalent DOT-117R-standard cars are required for service of crude oil and ethanol as well as other flammable liquids in U.S. DOT’s Packing Group 1.
DOT-117 Required for All Flammable Liquids
All jacketed and non-jacketed DOT-111 and all DOT-111 built to CPC-1232 standards are to be phased out of flammable liquid service, as required by the FAST Act.
Toxic Inhalation Hazards Timeline
Congress passes SAFTEA-LU
FRA is required to validate modeling of forces in accidents and implement appropriate design standards for pressurized tanks.
Next Generation Rail Tank Cars (NGRTC) Project Announced
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.
AAR Issued Three TIH-Related Circulars
FRA Signed Memorandum of Cooperation with NGRTC Project
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
HM-246 Interim TIH Standard Proposal – NPRM
This NPRM proposed that cars built for TIH service be capable of surviving both head and shell puncture tests. These new designs had to be implemented within 8 years after the rule was finalized. See HM-246 NPRM
P-1525 Industry Petition for Interim TIH Standard
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.
Next Generation Rail Tank Car (NGRTC) Project Concluded
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).
HM-246 Interim TIH Standards Final Rule
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) is Formed
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]
ATCCRP Program Conclusions
The Advanced Tank Car Collaborative Research Program (ATCCRP) investigated a broad spectrum of technologies that had the potential to improve the safety and security of tank cars and development conclusions. [Read the Conclusions]
ATCCRP Petitioned the DOT to Adopt the Interim Standards as Final
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]
AAR Petitioned DOT for a Six-Year Phase Out of the Legacy TIH Fleet
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]
CPC-1325 TCC Issued Six-Year Phase Out of Legacy TIH Cars
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]
DOT Accepted ATCCRP Petition for Adoption of HM-246 Interim TIH Standard as Final
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.