Coincident with a press conference given by Lisa Raitt (Canadian Minister of Transportation) and her US counterpart, Anthony Foxx (US Secretary of Transport), Transport Canada published an amendment to the TDGR on their “Adopted amendments…” website on May 1.
Presumably we can expect to see the official publication in an upcoming CGII. One would expect that, given the press conference it may be out in the next (May 6) edition- but the first deadline of the phase in is October 1, 2015.
Phasing in Upgrades
The main part of the amendment outlines the mandatory use of upgraded design TC 117 rail tanker cars spurred by the TSB (Transportation Safety Board) recommendations post Lac-Mégantic, and subsequent incidents in the intervening period. All rail cars manufactured after October 1, 2015 must be to the TC 117 standard if they are to be used for Class 3 flammable liquids. Other features of the phase-in (TC 117)/phase-out (TC/DOT111) requirements will transition for deadlines ranging from April 30, 2017 to April 30, 2025:
Chart of Phase-In
| Last Day to Use Tank Car in Column 3 for Dangerous Goods in Column 2 | Flammable Liquid / Packing Group(s) (PG) | Tank Car Type removed from Service | North American Fleet to be Retrofitted | Canadian Tank Car Population |
|---|---|---|---|---|
| April 30, 2017 | Crude Oil (PG I, II, III) |
DOT-111 Non-Jacketed |
After 28% Retirement Rate 16,625 | 4988 |
| February 28, 2018 | Crude Oil (PG I, II, III) |
DOT-111 Jacketed |
After 28% Retirement Rate 5,027 | 2759 |
| March 31, 2020 | Crude Oil (PG I, II, III) |
DOT-111 Non-Jacketed |
21,993 | 6849 |
| April 30, 2023 | Ethanol (PG II) |
DOT-111 Non-Jacketed |
After 28% Retirement Rate 19,467 | 974 |
| April 30, 2023 | Ethanol (PG II) |
DOT-111 Jacketed |
88 | 0 |
| June 30, 2023 | Ethanol (PG II) |
DOT-111 Non-Jacketed |
751 | 0 |
| April 30, 2025 | Crude Oil and Ethanol and all remaining Flammable Liquids (PG I, II, III) |
CPC 1232 Jacketed in Crude Oil service and all remaining DOT-111 Jacketed and CPC 1232 Jacketed and Non-Jacketed tank cars | 35,631 in crude oil service After 28 % retirement rate for older TC/DOT 111 tank cars 28,600 |
10,698 CPC 1232 Jacketed 8,580 in Flammable liquid service other than crude & ethanol |
This chart can be found on p.13 of the RIAS
The majority of the amendment will be invoking these deadlines by sub-clauses in Part 5.14-5.15 referring to the TC 117 cars and related sections of TC Standard TP14877.
No need to go overboard on combustibles:
Special Case 1.34 is also being amended to exclude requiring rail shipments of combustible liquids treated “as flammable” from following ERAP requirements and certain other flammable liquid tank car requirements.
New ERAP Correction:
Another welcome feature of the amendment will correct an earlier awkwardness that would have seen IBC, highway tankers, etc. subject to ERAP requirements (see my Blog of March 10, 2015).
A new special provision 150 has been added to the affected UN numbers in Schedule 1, with a corresponding entry in Schedule 2.
Simultaneously, the 10,000 L entries for these UN numbers in Column 7 of Schedule 1 have been removed.
(Those with the foresight to subscribe to our amendment service will be getting their money’s worth in 2014/2015!)
The summary of these changes and links to the detailed amendment/RIAS (regulatory impact analysis statement) are on the Transport Canada website:
http://www.tc.gc.ca/eng/tdg/clear-modifications-adopted-90.htm
The Minister & Secretary also reviewed some other issues regarding information sharing on routes, speed limit reductions and general harmonization.
The 40 minute video (which actually starts about 5 minutes in after some fiddling with the flags) is embedded below:
https://youtube.com/watch?v=WaBh-sJjhvc%3Frel%3D0%26w%3D500
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