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To: BNSF Railway Customers
10/08/2013

DOT Hazard Class, Packing Groups and Authorized Tank Cars

BNSF Railway is sharing the latest industry trends to ensure safe transport of hazardous materials. It is widely understood that rail remains one of the safest ways to move hazardous materials, with over 99.997 percent of shipments arriving at their destination without incident.
 
Recently, concern has surfaced about whether shippers are properly classifying crude oil on shipping papers. The U.S. Department of Transportation (DOT) began measures to test for compliance.
 
The DOT sent a letter on July 29, 2013, to the American Petroleum Institute. Click here to view the letter.
 
Currently, the DOT is conducting spot field inspections and sampling crude oil at shipping terminals. Their effort is focused on ensuring proper selection of the Packing Group (PG) for crude oil based on its flashpoint and boiling point and the practice of proper tank car selection.
 
BNSF recommends that crude oil shippers ensure proper Packing Group classification by developing and applying a system to accurately ascertain the flashpoint and boiling point of each shipment to satisfy regulatory requirements.
 
To develop a safer DOT111 tank car, the Association of American Railroads’ Tank Car Committee (AAR-TCC) changed the requirements for new tank car manufacturing for Class 3 flammable PG I and PG II materials. The change is predicted to reduce the risk of a release from a derailed tank car. The AAR, on behalf of the AAR-TCC, petitioned DOT in 2011 to adopt proposed standards for new tank cars. In July 2011, AAR adopted higher standards for all new tank cars ordered (not manufactured) after Oct. 1, 2011, for shipment of crude oil and ethanol (CPC1232). The AAR-TCC sought new tank cars to meet a higher safety standard.
 
The DOT has yet to adopt AAR’s petition for new DOT111 cars. As a result, the older style DOT111 car is currently allowed by DOT to move PG I and PG II flammable liquids (including crude oil). This is allowed despite the fact that the older style is not equipped with rollover protection or other features in AAR’s proposed "enhanced" design.
 
Be advised the DOT announced an Advanced Notice of Proposed Rulemaking (docket PHMSA-2012-0082-0016) for tank car standards. Click here to learn more about the rulemaking. 
 
In light of these recent developments, BNSF has attached answers to Frequently Asked Questions (FAQ) in order to provide additional clarification. 


If you have any questions, please send an email to Customer.Notifications@bnsf.com