KEY TAKEAWAY

Freight railroads have long been committed to the safe transportation of hazardous materials. During the early 1900s, a predecessor of the AAR Tank Car Committee (TCC) began developing tank car specifications as part of a voluntary industry effort to improve safety. The TCC continues to help ensure safe hazmat movement today through actions like technical design review and industry-wide interchange standard setting.

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The April 2023 TCC Meeting was held from April 17-20 at the Westin Denver Downtown located at 1672 Lawrence Street, Denver, CO (303-572-9100).

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In 1927, the Interstate Commerce Commission, the precursor to the Surface Transportation Board, not only adopted these standards but also required that the TCC approve future tank car designs before construction or modification because of the TCC’s technical expertise. The TCC continues to perform these safety-critical functions and remains essential to safely transporting hazardous materials.

The current oversight system for rail tank cars is multi-faceted, with federal minimum standards sometimes being exceeded by industry best practices. In this system, the Department of Transportation (DOT) retains regulatory authority over rail transportation safety, including setting minimum specifications for tank cars. Due to its technical expertise, DOT has delegated its authority on certain tank car safety matters to the TCC, including technical design review. AAR approval of facilities’ quality assurance programs is also a regulatory requirement.

Separate from these regulatory references, the TCC also reviews and sets industry-wide interchange standards for the design and operation of tank cars in North America under the voluntary agreement of the rail industry. While these interchange standards can sometimes require the tank car industry to exceed, or more quickly meet, DOT’s regulations, they can never relax DOT’s minimum requirements or degree of oversight.

This system has ensured that today’s tank cars are built with better thermal protection, higher grade steel, and better valves and fittings. It has improved tank car safety at an otherwise impossible speed through the traditional regulatory process. As a result of these efforts, as well as the rail industry’s well above $23 billion a year over the past five years in investments for infrastructure and technological innovation, rigorous employee training, and community safety efforts, more than 99.9% of rail hazmat shipments have reached their destination without a train accident-caused release and the hazmat accident rate is down 78% since 2000 to an all-time low.

Because no one railroad covers the entire country, railroads are often required to interchange equipment, including tank cars, during their operations to transport goods to their destinations. To facilitate these interchanges, the rail industry, including rolling stock owners and repair facilities, voluntarily agreed to accept and transport shipments that meet a consistent set of standards contained in the Manual of Standards & Recommended Practices (MSRP).

The TCC comprises representatives from the railroads, shippers, and tank car builders and owners. Additionally, representatives from the Federal Railroad Administration, PHMSA, the National Transportation Safety Board, Transport Canada, and the Transportation Safety Board of Canada regularly attend and participate in many of the TCC’s quarterly meetings.

Railroads generally do not own the tank cars they transport; instead, tank cars are often purchased and maintained by shippers or equipment leasing companies. Railroads, as common carriers, are obligated to transport any freight, including hazardous materials, properly tendered on reasonable terms and conditions.

In 2016, a group of shippers and tank car owners filed a petition for rulemaking with PHMSA that challenged the current system of oversight for rail tank cars and requested PHMSA to adopt regulations prohibiting any entity from requiring compliance with tank car specifications more rigorous than the minimum DOT safety standards. The filing of this petition was in direct response to efforts by the TCC to adopt improved standards for tanks used to transport toxic inhalation hazards.