Review - FRA Publishes Hot Bearing Wayside Detector Safety Advisory Update

Today, the DOT’s Federal Railroad Administration (FRA) published a safety advisory update in the Federal Register (89 FR 58243-58245) on “Safety Advisory 2023-01; Evaluation of Policies and Procedures Related to the Use and Maintenance of Hot Bearing Wayside Detectors (Second Supplement)”. The original advisory was published on March 3^rd, 2023 and then updated on June 14^th, 2024. This latest supplement expands on the recommendations to incorporate the findings of FRA's ongoing evaluations by emphasizing:

•The importance of trend analysis and the opportunity to integrate wayside detector data types to evaluate railcar health,

•The need to establish and follow appropriate processes in analyzing and responding to HBD data,

•The need for railroads to ensure that adequate staff are assigned to monitor and respond to wayside detector data, and

•The need for railroads to maximize the use of HBD data, including sharing wayside detector data between railroads, as a train travels from one railroad's tracks to another railroad's track.

 

For more information on today’s supplement, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/fra-publishes-hot-bearing-wayside - subscription required.

FRA Publishes Another Train Operations Safety Advisory – 4-27-23

Today, the DOT’s Federal Railroad Administration (FRA) published on their website a new safety advisory dealing with the operation of long trains. The instructions to railroad operators will not become official until they are published in the Federal Register, probably next week but, since these are non-regulatory instructions, that delay is not material.

Reacting to three recent long-train derailments (not including the East Palestine derailment) the advisory provides eight recommendations pending completion of two formal studies about safety issues related to the operation of long-trains. None of the recommendations is going to have an immediate impact on operational safety.

I’ll have more details when the official version is published and I can provide paragraph links in the discussion.

FRA Publishes Hot Wheel Bearing Safety Advisory

Yesterday, the DOT’s Federal Railroad Administration (FRA) published a notice of Safety Advisory 2023-01 in the Federal Register (88 FR 13494-13497) for “Evaluation of Policies and Procedures Related to the Use and Maintenance of Hot Bearing Wayside Detectors”. This safety advisory is at least partially in response to the recent derailment with fire and explosions near East Palestine, OH.

After reviewing background information on the use of hot bearing wayside detectors and how some recent derailments were presaged by ‘hot bearing detector’ (HBD) warnings (Warner Robins, GA, 7-12-22; Sandusky, OH, 10-8-22; and East Palestine, OH, 2-3-23), the Advisory discusses “Journal Bearings and Detecting Journal Bearing Defects”.

Based on the information discussed above, the Advisory goes on to recommend that railroads:

Review existing HBD system inspection and maintenance policies and procedures for compliance with existing industry standards and manufacturer recommendations for HBDs,

Review existing procedures to train and qualify personnel responsible for installing, inspecting, and maintaining HBDs to ensure they have the appropriate knowledge and skills,

Review current HBD detector thresholds in light of recent derailments, and all other relevant available data (including data from any close calls or near misses), to determine the adequacy of the railroad's current thresholds,

Review current procedures governing actions responding to HBD alerts to ensure required actions are commensurate with the risk of the operation involved, and

With regard to trains transporting any quantity of hazardous materials, FRA recommends railroads adopt the procedures outlined in AAR's OT-55 for key trains as an initial measure.

All of the discussions and recommendations described above were preceded by the following disclaimer:

“This Safety Advisory is considered guidance pursuant to DOT Order 2100.6A (June 7, 2021). Except when referencing laws, regulations, policies, or orders, the information in this Safety Advisory does not have the force and effect of law and is not meant to bind the public in any way. This document does not revise or replace any previously issued guidance.”

 

Perhaps it is time for Congress to specifically require FRA to establish regulations that require the use of wayside detectors and to ensure that they are tied into positive train control (PTC) systems where such systems exist.

PHMSA Publishes New Hazmat Railcar Safety Advisory

Today, DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) published a “Safety Advisory Notice for Tank Cars Equipped with Aluminum Manway Protective Housing”. PHMSA is recommending that “all hazmat tank car owners and offerors to survey their fleets for any tank cars currently equipped with aluminum protective housing and consider replacing this equipment with carbon steel housings, which we understand to be current industry practice.”

This advisory is being issued due to a report published today by the National Transportation Safety Board about their ongoing investigation of the East Palestine, Ohio derailment last month. That report notes that:

“The five derailed railcars carrying vinyl chloride were DOT-105J300W tank cars. Based on damage assessment inspections of these tank cars, the NTSB is concerned that aluminum protective housing covers on some tank cars melted or were consumed when pressure relief devices (PRDs) vented burning gas while functioning as designed to relieve tank pressure. Preliminary examination suggests that melted aluminum may have dripped into some PRDs, possibly degrading their performance.”

Review - FRA Publishes PTC Safety Advisory – 9-2-21

Today the DOT’s Federal Railroad Administration published a notice of safety advisory in the Federal Register (86 FR 49410-49411) for “Positive Train Control Interface Design Issue With Locomotive and Cab Car Braking Systems”. Safety Advisory 2021-01 was published due to the identification of the availability of a manual bypass of the PTC breaking controls on at least two different PTC systems.

It is easy to imagine circumstances where being able to defeat the PTC’s operation of breaking controls would be necessary. The system to defeat that system should not, however, be readily available to the train crew. Management review of the circumstances needs to be undertaken to ensure that the safety of the train, the crew and the public is protected.

For more details on the problem and FRA required actions, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/fra-publishes-ptc-safety-advisory - subscription required.

PHMSA Publishes Gas Cylinder Safety Advisory

Today the DOT’s Pipeline and Hazardous Material Safety Administration published a safety advisory in the Federal Register (80 FR 23851-23852) concerning unauthorized certification

of compressed gas cylinders.

PHMSA reports that between April 1986 through October 2014 that Liberty Industrial Gases and Welding Supplies Inc did not properly test ICC, DOT-Specification, or DOT-Special Permit cylinders that were presented for re-certification. Lacking proper testing, PHMSA considers that these cylinders are not safe for the transportation of hazardous materials. Cylinders marked by Liberty should be immediately taken out of service and emptied in an appropriate manner. Cylinders should be re-certified by a DOT-authorized cylinder requalifier to ensure their suitability for continued service.

To make matters more complicated, PHSA reports that Liberty marked the cylinders with the Requalifier Identification Number (RIN) of an approved requalifier. While the safety advisory only applies to cylinders marked by Liberty, unless the owner of the cylinder can specifically trace the requalification back to the approved requalifier, the cylinder probably should be assumed to have been marked by Liberty and appropriate action taken.

Anyone with a cylinder marked with the RIN of A890 with a date prior to October 2014 should contact the owner to determine the requalification status of the cylinder.

DOT Takes Additional Actions on Crude Oil Trains – Accident Information

This is part of a detailed look at several actions that the Department of Transportation (DOT) took last Friday to reduce the hazards associated with the transport of crude oil and other flammable liquids by train. Earlier posts in this discussion include:

DOT Takes Additional Actions on Crude Oil Trains

DOT Takes Additional Actions on Crude Oil Trains – FRA EO 30

DOT Takes Additional Actions on Crude Oil Trains – Incident Report ICR

This post looks at a joint Safety Advisory published by the Pipeline and Hazardous Material Safety Administration (PHMSA) and the Federal Railroad Administration last Friday (and it is scheduled to be published in the Federal Register tomorrow).

The SA reminds railroads that the FRA and PHMSA have authority to investigate railroad accidents, particularly those involving hazardous material. As part of that investigation process they have the legal authority to demand information from the railroad and affected shippers of hazardous materials. As a matter of advance notice, the SA provides a list of the type of information that they routinely expect to request for accidents involving crude oil train cars or other flammable liquid accidents. Those include:

∙ Information on train consist;

∙ Waybill;

∙ Safety Data Sheet;

∙ Results of product testing used to categorize flammable material;

∙ Results of product testing of railcar samples;

∙ Date of Acceptance;

∙ Company extracting crude oil;

∙ Company doing initial categorization testing;

∙ Company hauling crude oil or other flammable liquid to loading facility; and

∙ All railroads handling affected railcars;

The ‘train consist’ information would include:

∙ Train number;

∙ Locomotives;

∙ Locomotives as distributed power;

∙ End-of-train device information;

∙ Number and position of tank cars in the train;

∙ Tank car reporting marks;

∙ Tank car specification and ‘relevant attributes’

Commentary

A lot of the product related information included in the above list is going to be unique to crude oil shipments because of the increased testing in the latest version of EO 28 issued last year. Manufacturers of flammable liquids do not have to test every load to confirm the classification and packing group of the material. They can use standard information on the product. The oil industry used to be able to do this, but spot checks by PHMSA indicated that there were a number of cases where those assumptions were wrong.

At this time this information is only needed on an ‘on demand’ basis in the event of a rail accident involving crude oil or other flammable liquids (mainly targeting ethanol, but that distinction is not made in this SA). It seems likely that at some point FRA will consider a formal documentation requirement for all crude oil railcars from point of extraction to delivery to the refiner.

DOT Takes Additional Actions on Crude Oil Trains

Today the Department of Transportation published six new documents outlining new actions that PHMSA an FRA were taking to reduce the risks associated with the transportation of crude oil and other flammable liquids in unit trains or blocks of cars. The new documents are:

∙ PHMSA Notice – Emergency Response Information Requirements

∙ PHMSA Safety Advisory – Railroad Flammable Liquid ER Information Requirements

∙ FRA Emergency Order – Maximum Speed Limit for HHFT in HTUA

∙ FRA Safety Advisory – Wheel Inspection Requirements for HHFT

∙ FRA ICR Notice Change – Incident Report

∙ FRA Letter to AAR

A DOT blog post by Secretary Foxx outlines the new requirements and actions being published today. These actions are being taken while the highly-hazardous flammable train (HHFT) rulemaking is still under review at the Office of Management and Budget. Congressional sources have said that the rulemaking is expected to be published on May 12^th, 2015.

PHMSA also has a new web page providing a history of actions that the Department has taken to date to increase the safe transportation of energy products.

There is also a note that FEMA is also addressing the emergency response information issue in a separate blog post.

I’ll have further information after I have had a chance to conduct a review of the documents.

New FRA-PHMSA Railroad Safety Advisory

Today the Federal Railroad Administration (FRA) and the Pipeline and Hazardous Material Safety Administration (PHMSA) published a new Joint Safety Advisory in the Federal Register (78 FR 69745-69746) concerning safety and security plans for shipping Class 3 (flammable/combustible) hazardous materials by rail. This is a follow-up advisory to the one issued in July and the FRA Emergency Order 28 that was issued as a result of the “catastrophic railroad accident [that] occurred in Lac-Mégantic, Quebec, Canada” on July 6th.

Reiterate Old Guidance

There is really no new guidance offered in this Advisory. The FRA and PHMSA are reiterating the requirements for:

• The proper characterization, classification, and selection of a hazardous materials packing group as required by the Federal hazardous materials law (49 U.S.C. 5101-5128) and Hazardous Materials Regulations (HMR; 49 CFR parts 171-177); and

• The requirement that offerors of hazardous materials by rail and rail carriers should have reviewed and revised, as appropriate, their safety and security plans required under Subpart I of Part 172 of the HMR, including the required risk assessments, to address the safety and security issues identified in EO 28 and the First Joint Advisory.

Compliance Auditing

The only new information in this advisory is in the final paragraph describing the enforcement activities that FRA and PHMSA are undertaking in support of this and the earlier safety advisory and Emergency Order. Those activities include:

• ‘Operation Classification’ - unannounced inspections and testing by PHMSA and FRA to verify the material classification and packing group assignments selected and certified by offerors of petroleum crude oil;

• PHMSA-FRA joint audits to evaluate safety and security plans and to determine whether the plans address vulnerabilities highlighted in EO 28 and the First Joint Advisory; and

• FRA inspections to determine compliance with EO 28.

Ignores Alabama Derailment

It is interesting that there is no mention in this Advisory of the FRA investigation into the recent derailment of a crude oil unit train in Alabama. While that accident did not result in the loss of life or the destruction of non-railroad property seen in Canadian derailment, it is the first such incident being actively investigated by FRA. Or at least should be being investigated by FRA, there has been no public announcement of any such investigation.