Yesterday the Pipeline and Hazardous Material Safety Administration (PHMSA) published a new Safety Advisory concerning rail shipments of crude oil. Because of three recent high-profile derailments and fires of crude oil trains (North Dakota, Alabama and Lac-Megantic, Quebec) PHMSA is conducting spot checks of crude oil to determine if the material is properly classified for shipment.
Petroleum Crude Oil (UN 1267) is listed in 49 CFR 172.101 as a flammable liquid (Class 3) with three possible packing groups based upon its characteristics. Those packing groups determine which types of rail cars may be used to transport the material with a Packing Group I requiring more rigorous protections based upon its higher risk. The testing that PHMSA has been doing has been aimed at determining if the material being shipped has been assigned to the proper shipping group.
Generally speaking 49 CFR 173.121 bases the packing group assignments for flammable liquids on the flash point (the lowest temperature at which ignition can take place) and boiling point of the liquid in question. A flammable liquid is generally classified (49 CFR 173.120) as “having a flash point of not more than 60 °C (140 °F)”. Packing Group I flammable liquids have an initial boiling point of less than 35 °C. Packing Group II flammable liquids have a flash point of less than 23 °C. And Packing Group II flammable liquids have a flash point of greater than 23 °C.
The additional testing by PHMSA as part of Operation Classification seems to indicate that this classification scheme may not be adequate for describing the relative risk associated with crude oil. While their testing program is not yet complete, the Safety Advisory indicates that they are looking at the possibility of requiring additional testing to possibly include:
• Reid Vapor Pressure;
• Hydrogen sulfide content; and
• Composition/concentration of the entrained gases in the material
PHMSA closes out their advisory with the following reminder:
“PHMSA also reminds offerors that the hazardous materials regulations require offerors of hazardous materials to properly classify and describe the hazardous materials being offered for transportation. 49 CFR 173.22. Accordingly, offerors should not delay completing their own tests while PHMSA collects additional information”
I expect that we will see this Safety Advisory officially published in the Federal Register next week.