This is a CN statement made Jan. 8, 2014, in response to questions from CBC News about the safety of the DOT-111 tanker cars:
Q: What is CN’s position on the need for enhanced standards for DOT-111 cars?
A: One of the key issues for CN and the entire North American rail industry is the review of tank car design. In CN’s view, tank car design is one of the most important systemic issues arising from the Lac-Mégantic accident. The question of tank car robustness is central, and that question is being addressed by the Association of American Railroads, to which CN belongs, in a recent recommendation that calls for the retrofitting or phase out of the old DOT-111 cars used to transport flammable liquids and a reinforced standard for new tank cars built in the future.
Q: Should these standards be applied to new, or new and existing DOT-111 tank cars?
A: CN, as a member of the AAR [Association of American Railroads], supports the AAR’s call of November 2013 urging the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) to press for improved tank car safety by requiring all tank cars used to transport flammable liquids to be retrofitted or phased out, and new cars be built to more stringent standards.
In comments responding to a PHMSA [U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration] advanced notice of proposed rulemaking, AAR recommended retrofit specifications aimed at significantly decreasing the likelihood of a release of hazardous materials by a tank car involved in an accident.
- Today roughly 92,000 tank cars are moving flammable liquids and approximately 78,000 of those might require retrofitting or phase out based on AAR’s proposal.
- Approximately 14,000 newer tank cars that today comply with higher safety standards also might require some upgrades.
AAR offered the following specific recommendations to PHMSA in determining what federal safety standard improvements should be required for tank cars moving flammable liquids:
- Increase federal tank car design standards for new cars to include an outer steel jacket around the tank car and thermal protection, full-height head shields and high-flow capacity pressure relief valves;
- Require safety upgrades to those tank cars built since 2011, when the rail industry instituted design standards that today exceed federal requirements, including installation of high-flow-capacity relief valves and design modifications to prevent bottom outlets from opening in the case of an accident;
- Aggressively phase out older-model tank cars used to move flammable liquids that cannot be retrofitted to meet new federal requirements, and
- Eliminate the option for rail shippers to classify a flammable liquid with a flash point between 100 and 140 degrees Fahrenheit as a combustible liquid.
Q3: Who should pay for these upgrades?
A: CN’s position is that tank car owners should pay for upgrades in the normal course of business.
Q4: How many DOT-111s are owned by CN (approx) as opposed to the numbers of fleet cars owned by other leasing companies, yet hauled by CN?
A: CN owns 36 DOT-111 tank cars and leases another 175 to transport diesel fuel to terminals for its locomotives. CN plans to replace these owned and leased tank cars with leased DOT-111 tank cars built to the latest regulatory standards.
Q5: What are the challenges, from CN’s perspective, on implementing new standards across Canada and the United States?
A: Ensuring new regulations are fact-based and consistently applied across the integrated North American rail industry.
Note that roughly 99.998 per cent of hazardous material carloads moving by rail arrive at their destination without a release caused by an accident.
Director -- Communications & Public Affairs
Canadian National Railway Company