On the 11th January 2014, Transport Canada’s regulatory arm proposed changes to the regulations governing the construction of railway tank cars in Canada, as well as for the cars operating there which may not have been constructed in country (i.e., primarily US built cars).
The proposed changes will conform the standard of construction to that found in Canada Standard TP14877, which itself is a harmonization with US requirements. This change primarily affects the large fleet of what are known as “DOT 111” tank cars—a type used mainly for the transport of flammable liquids. It was a loaded unit train of such cars carrying petroleum oil operating on the Montreal, Maine, & Atlantic Railroad (a US firm) that derailed and caught fire in Lac Megantic, Quebec, early last summer. The resultant flames, smoke, and spilling petroleum oil killed an estimated forty seven Canadian citizens and caused extensive damage to the center of the community, as well as contaminating major nearby water resources. A number of other and thankfully less serious derailments of similar trains have occurred in both Canada and the US since that event, prompting close scrutiny of tank car construction standards as well as railroad operating practices when dealing with hazardous materials (or dangerous goods, as they are known in Canada and elsewhere) by the regulatory agencies of both nations.
The new Canadian standard proposes the following items related to tank car construction:
- New requirements for half head-shields, increased thickness of the shell and heads, and top-fitting protection for new DOT-111 tank cars;
- Two new designs of cryogenic tank cars as well as a new design for tank cars carrying liquefied natural gas or ethylene refrigerated liquid, that are both currently only allowed in Canada through an equivalency certificate;
- Addition of a requirement for stub sill inspection;
- Additional safety features on tank cars carrying between 120,000 to 130,000 kilograms (i.e. 263,000 to 286,000 pounds) of dangerous goods; and
- Increase pressure relief valve requirements on aluminum tank cars to reduce non-accidental releases; therefore, reducing a worker’s risk of being exposed to the dangerous goods.
In the United States, similar new construction standards are being promoted by the American Association of Railroads (AAR), so it is more rather than less likely that the standards of both nations will end up being extremely similar to one another—a stated goal of the Canadian action. To what extent “grandfathering” of the existing fleet of DOT 111 cars may occur if the new regulation takes effect remains unclear. Refit of existing cars will be very costly and current AAR estimates of some 92,000 units in service will make any such action a long term project. Tank cars tend to be owned by shippers and/or leasing firms as opposed to directly by railroads, so the massive cost of such a refit program will be borne primarily downstream of such users.
The new Canadian action further mirrors US efforts through its additional emphasis on correct classification of the consigned dangerous goods when they are proffered to a transport company. In the US, a new Pipeline & Hazardous Materials Safety Administration (PHMSA) initiative titled “Operation Classification” is underway (see my previous blog post in reference thereto) to enforce stricter adherence to existing classification rules. The Canadian proposal requires increased documentation, recordkeeping, and certification of such consignments, and specifically mentions crude oil.
All of the above actions are largely in response to the Lac Megantic accident. Ironically, modification of the standards surrounding new construction of units for the two nations’ railway tank car fleets for safer operation was already very much “in the works” prior to the tragedy; however, the scale of the accident and resultant loss of life has spurred regulatory action on a scale and at a speed that is rare within the regulated community.
Here is a link to the Canadian proposal:
http://gazette.gc.ca/rp-pr/p1/2014/2014-01-11/html/reg1-eng.html
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