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Rule Summary: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains

The long awaited final rule for Crude-by-Rail transportation was released today by DOT/PHMSA. The major new requirements includes the need for Electronically Controlled Pneumatic (ECP) Brakes, 9/16" shell thickness, and an extended timeline schedule for implementation (retrofits), train route disclosures, and other requirements:

(Update: Union Pacific threatens lawsuit over the contrived ECP requirements (new braking system which is said to be very expensive, difficult to implement)).

Below is a summary of the key provisions contained in the May 1, 2015 Final Rule, "Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains," issued by the Pipeline and Hazardous Materials Safety Administration and the Federal Railroad Administration.

Scope of Rulemaking
  • Unless stated otherwise, the rule applies to “High-hazard flammable trains” (HHFT) which means “a continuous block of 20 or more tank cars loaded with a flammable liquid or 35 or more tank cars loaded with a flammable liquid dispersed through a train.”

Enhanced Braking
  • Require HHFTs to have in place a functioning two-way end-of-train (EOT) device or a distributive power (DP) braking system.

  • Require any high-hazard flammable unit train (HHFUT) —a train comprised of 70 or more loaded tank cars containing Class 3 flammable liquids traveling at greater than 30 mph— transporting at least one packing group I flammable liquid be operated with an electronically controlled pneumatic (ECP) braking system by January 1, 2021.

  • Require all other HHFUTs be operated with an ECP braking system by May 1, 2023.

Enhanced Standards for New and Existing Tank Cars Used in HHFTs

  • New tank cars constructed after October 1, 2015 are required to meet enhanced DOT Specification 117 design or performance criteria for use in an HHFT.

  • Existing tank cars must be retrofitted in accordance with the DOT-prescribed retrofit design or performance standard for use in an HHFT.

  • Retrofits must be completed based on a prescriptive retrofit schedule. The retrofit timeline focuses on two risk factors, the packing group and differing types of DOT-111 and CPC-1232 tank car.

  • A retrofit reporting requirement is triggered if consignees owning or leasing tank cars covered under this rulemaking do not meet the initial retrofit milestone.

Reduced Operating Speeds
  • Restrict all HHFTs to 50-mph in all areas.

  • Require HHFTs that contain any tank cars not meeting the enhanced tank car standards required by this rule operate at a 40-mph speed restriction in high-threat urban areas defined the Transportation Security Administration’s regulations at 49 CFR 1580.3.

More Accurate Classification of Unrefined Petroleum-Based Products
  • Document sampling and testing program for all unrefined petroleum-based products, such as crude oil.

  • Certify that programs are in place, document the testing and sampling program outcomes, and make information available to DOT personnel upon request.

Rail routing - Risk Assessment

  • Railroads operating HHFTs would be required to perform a routing analysis that considers, at a minimum, 27 safety and security factors and select a route based on its findings. These planning requirements are prescribed in 49 CFR § 172.820.

Rail routing – Information Access

Ensures that railroads notify State and/or regional fusion centers, and that State, local and tribal officials who contact a railroad to discuss routing decisions are provided appropriate contact information for the railroad in order to request information related to the routing of hazardous materials through their jurisdictions.


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