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Hazmat Safety Advisory: Flammable Liquids by Rail

Posted on 3/31/2023 by Roger Marks

US DOT PHMSA, together with the Federal Rail Administration (FRA), issued a hazardous materials Safety Advisory related to DOT-111 specification rail tank cars in flammable liquid service recently.

The advisory follows the derailment and large hazardous materials release in East Palestine, OH on February 3, and several (less severe) incidents involving hazmat on the rails in the two months since.

The notice, issued on March 22, reminds the regulated community that concerns exist about the DOT-111 tank car's ability to survive an incident without a breach/hazmat release. Those concerns led PHMSA (and the FRA) to begin a phase-out and/or mandatory retro-fit schedule for DOT-111 tank cars years ago, which is still ongoing. 

The hazmat safety advisory urges tank car owners and/or shippers to: 

  • Voluntarily replace their DOT-111 tank cars with “the newest, and safest, available tank car design authorized for flammable liquid service—the DOT-117 specification tank car.” 

  • Follow the requirements for high-hazard flammable trains (HHFTs) for trains carrying flammable liquids in DOT-111 tank cars, even if the train has fewer cars than an HHFT.*  

See the Safety Advisory Notice in full here.

DOT-111 Tanks Cars in Ohio Hazmat Incident 

Thirty-eight rail tank cars left the tracks in East Palestine, OH on February 3, 2023. Of those thirty-eight, sixteen were DOT-111 tank cars—and of those, seven were breached. Three of the DOT-111 tank cars involved were carrying hazardous materials, and all three released hazmat from certain spots on the car.

“The preliminary incident data released by the Environmental Protection Agency (EPA) highlights that the performance of DOT-111 specification tank cars involved in the derailment continues to be a significant concern.” 

Safety Advisory Notice for DOT-111 Tank Cars….
US Dept. of Transportation, 03/22/23

Hazmat Safety Advisory: Flammable Liquids by Rail

Industry stakeholders and regulators have long voiced concerns about the structural integrity of the DOT-111 tank car used in flammable liquid service during an incident (like a derailment). In 2015, PHMSA finalized new requirements for shipping flammable liquids by rail that included a schedule for upgrading DOT-111 tank cars used to transport Class 3 hazardous materials.

*What is a high hazard flammable train (HHFT)?

A term created in PHMSA's 2015 rulemaking to enhance the safety requirements for flammable liquids by rail,  a high-hazard flammable train or HHFT is, in a general sense, a train with a lot of cars on it carrying flammable liquids. 

An HHFT is a train with:

  • 20 or more cars carrying flammable liquids in a continuous block, or 
  • 36 or more cars carrying flammable liquids on an entire train. 
The rail shipping regulations added in 2015 include speed restrictions, enhanced-safety routing requirements, recordkeeping requirements, and more for high hazard flammable trains. 

See the Safety Advisory Notice in full here.

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Tags: East Palestine, Ohio, hazardous materials, hazmat incident

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