Timeline - Tank Car Resource Center


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HM-251/FAST Act Timeline

Jul, 2009

Railway Supply Institute Joins Task Force

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.

Mar, 2011

Rulemaking 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 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]

Oct, 2011

Voluntary Action

The railway supply industry voluntarily implements the enhanced Class-111 tank car standard for newly ordered cars for ethanol and petroleum crude oil service in packing groups I and II. [View CPC-1232 Standard]

Sep, 2013

ANPRM Under Docket HM-251

PHMSA publishes an Advanced Notice of Proposed Rulemaking (ANPRM) under Docket HM-251, regarding regulatory revisions to improve the transportation of flammable liquids in railroad tank cars. [View Document]

Dec, 2013

RSI Comments Under Docket HM-251

The Railway Supply Institute (RSI) submits comments to PHMSA under Docket HM-251, laying out its recommendations regarding new and existing tank car standards. [View Document]

Feb, 2014

RSI Meets with DOT

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]

Mar, 2014

PHMSA Testifies on Need for Prevention

PHMSA Administrator Cynthia Quarterman states at a Senate hearing on rail safety that a comprehensive approach is needed and that regulators “need to first concentrate on prevention” of train derailments. [View Hearing]

Apr, 2014

RSI Meets with Transport Canada

RSI meets with Lisa Raitt, Canadian Minister of Transport, to present its recommendations on changes to the tank car standards and to encourage harmonization of the U.S. and Canadian regulations. [View Follow-Up Letter]

Jun, 2014

RSI-CTC Meets With OMB

RSI-CTC meets with the White House Office of Management and Budget (OMB) regarding the impact of the new tank car standards, tank car production and retrofit capacity considerations, and RSI-CTC’s recommendation proposal to PHMSA. [View Outline]

Jul, 2014


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]

May, 2015

RSI-CTC Press Release Final Rule – Crude by Rail Regulation

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]

Dec, 2015

FAST Act Signed into Law

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]

Jun, 2016

Ninety-seven Percent of DOT-111 Removed from Crude Oil Service

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]

Jul, 2016

Canada’s Minister of Transport Accelerates DOT-111 Phase-Out Schedule

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.

Nov, 2016

Class-111 Removed From Crude Oil Service in Canada

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]

Jan, 2018

First FAST Act Deadline

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.

Mar, 2018

Jacketed Class-111 Deadline for Crude Oil Tank Cars

As required by the FAST Act, all jacketed Class-111 tank cars were no longer in crude oil service.

Aug, 2018

Canada Accelerates Phase Out Timeline

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]

Sep, 2018

DOT Removed ECP Brake Requirements

DOT removes the ECP brake requirement for High-Hazard Flammable Liquid Unit Trains. [Read Federal Register Notice here]

Apr, 2020

Deadline for Non-Jacketed Enhanced Class-111 Tank Cars in Petroleum Crude Oil

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.

May, 2023

Legacy Class-111 Phased Out of Ethanol Service

As required by the FAST Act, all legacy jacketed and non-jacketed Class-111 are to be phased out of ethanol service.

Jul, 2023

Non-Jacketed Enhanced Class-111 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.

May, 2025

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.

May, 2029

Class-111 Tank Cars Prohibited Transporting All Flammable Liquids

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

Aug, 2005

Congress passes SAFTEA-LU

FRA is required to validate modeling of forces in accidents and implement appropriate design standards for pressurized tanks.

May, 2006

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.

Dec, 2006

AAR Issued Three TIH-Related Circulars

Between July and December 2006, AAR issued CPC-1175, CPC-1176 and CPC-1178, requiring more robust tank specifications for anhydrous ammonia and chlorine, new car specifications and phase-out proposals.

Jan, 2007

FRA Signed Memorandum of Cooperation with NGRTC Project

FRA sponsored two full-scale impact tests during 2007.

Mar, 2008

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

Apr, 2008

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

Jul, 2008

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.

Sep, 2008

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).

Jan, 2009

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.

Jan, 2009

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] 

Nov, 2016

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]

Dec, 2016

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]

Dec, 2016

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]

Apr, 2017

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]

Sep, 2017

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.