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HM-251/FAST Act Timeline
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.
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]
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 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]
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]
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]
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]
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]
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.
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.
All jacketed DOT-111 have been removed from crude oil service, as required by the FAST Act.
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]
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.
All jacketed and non-jacketed DOT-111 carrying ethanol are to be phased out of service, as required by the FAST Act.
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 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.
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
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.
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.
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.