Loading, Unloading, and Transloading Hazmat Rail Shipments
If so, you are subject to the rules at 49 CFR Part 174, which regulate the loading, moving, and unloading of hazardous materials by rail. These rules—including DOT hazmat training requirements—apply to the railroad operators who transport the goods, shippers who prepare rail cars for transport, and receivers (consignees) who must properly unload the cars and prepare the “empties” for return shipping.
Hazardous materials shipped by rail can be packed in drums, IBCs, or other bulk or non-bulk packagings packed inside box cars or strapped to flat cars. Hazmat shipped by rail can also be shipped in rail tank cars or, simply, “tank cars.” 49 CFR Part 174 lays out specific rules for each type of container that can be used to ship hazmat by rail. The rules for bulk and non-bulk packagings by rail are largely similar to the rules for shipping them by motor vehicle.
Shipping hazmat by tank car, however, is a little bit different.
Shipping Hazmat by Rail Tank CarIf you are using tank cars to ship hazmat, then you must load, unload, or transload them at some point. You’re probably aware of the terms “loading” and “unloading” already, and we will discuss these below.
“Transloading” refers to the transfer of hazardous material (for the purpose of continuing the movement in commerce) from:
- One bulk packaging to another bulk packaging (e.g., tank car to tank car);
- A bulk packaging to a non-bulk packaging (e.g., tank car to drum); or ·
- A non-bulk packaging to a bulk packaging (e.g., drum to tank car).
When moving any kind of hazardous material from one container or package to another, the risk of a spill is very real. To prevent spills or accidents during loading, unloading, or tranloading of hazmat, DOT sets specific, unique requirements that hazmat employees must follow before, during, and after performing these job functions.
Before Loading, Unloading, or Transloading [49 CFR 173.31]Before a tank car can be loaded or transloaded:
1. The shipper must choose an authorized tank car that meets all applicable specifications and is the right size and type for the material you’re shipping;
2. The periodic inspection date marked on the tank car must be current; and
3. The tank car must be inspected by the loader to ensure it’s in good condition for use.
And, before a tank car is loaded, transloaded, or unloaded, the following steps must be followed:
- Ensure that all closures on the tank car are closed and made “tool-tight” by the use of a bar, wrench, etc.
- Secure access to the tracks to prevent entry by other rail equipment.
- Post caution signs between the rails.
- Prevent the car from movement (setting handbrakes and blocking wheels).
- Relieve tank car pressure (if applicable).
- Securely attach connections before opening any valves.
Loading, Unloading, and Transloading [49 CFR 174]Trained operators are responsible for following specific written safety procedures when loading, unloading, and transloading tank cars. General rules for loading, securing, segregating, and separating hazardous materials must also be followed.
For certain hazard classes—gasses , flammables, inhalation hazards, explosives, and radioactives—additional precautions must be taken. These materials are subject to more rules in 49 CFR 174 than other hazmat.
While loading, unloading, or transloading hazmat to or from a tank car, the tank car is being loaded, unloaded, or transloaded, and with few exceptions while unloading equipment is attached, the tank car must either be:
1. Attended by a designated hazmat employee who is physically present and has an unobstructed view of the operation; or
2. Be monitored by a signaling system that is observed by a designated hazmat employee who is located either in the immediate area of the tank car or at a remote location within the facility.
After Loading, Unloading, or TransloadingWhen loading, unloading, and transloading is complete, all closures must be “tool-tight” and connections removed. If the tank car is going to be transported, it will need to be inspected again, and all rail cars carrying hazmats must be marked and placarded appropriately per 49 CFR 172.
Convenient DOT Hazmat Online Training for Rail ShippersIf you are responsible for loading, unloading, and transloading tank cars, or if you ship, carry, or receive hazmat by rail, keep up to date with these rules and more with Lion’s new Hazmat Ground Shipper—Additional Rail Requirements online course. Designed to meet DOT’s function-specific hazmat training, the course covers critical 49 CFR rules for shipping hazmat by tank car, freight container, IBC, and bulk or non-bulk packages by rail.
* 2012 United States Hazardous Materials Economic Census Transportation Commodity Flow Survey
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