If you ship hazardous materials by rail there are a lot of things you have to take into consideration in addition to the standard requirements of all HazMat shippers. These include:
- The requirements and limitations on the use of tank cars for specific HazMat at 49 CFR 173.10
- The requirements for loading/unloading and preparing tank cars for transportation at §173.31.
- The marking requirements for tank cars and multi-unit tank car tanks at §173.330.
- The additional planning requirements for transportation by rail at §172.820 within the existing regulations for a Safety and Security Plan in Subpart I of Part 172.
- The option for use of an electronic shipping paper available at §172.201(a)(5).
…and others found throughout the Hazardous Materials Regulations.
While the guidance below will not ensure complete compliance with the HMR, it will assist a shipper of HazMat by rail to identify the best practices to achieve compliance.
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- Develop and implement a securement policy which includes pre-loading inspections, post-loading inspections and corresponding safety checklists.
- Special attention should be given to ensure that no overloading of rail cars occurs, especially hazardous materials.
- Perform extra inspections of valves and manways for tightness (one of the leading causes of leaks/spills in rail transportation incidents).
- After loading, leak-test the car by applying at least 10 psig of pressure over the maximum estimated transportation pressure. all valves, packing gland nuts, closures and flanges should be checked using leak detection solution or ultrasonic instrument. After completing the leak test, pressure should be released or reduced.
- If a pressure test is impractical or unsafe, the car should be held and reinspected after twenty-four (24) hours, and valves and fittings tightened as needed to ensure proper securement.
- Review shipping papers to ensure the proper information is provided.
- Promote electronic data interchange (EDI) for all shipments.
- Ensure that proper placarding is maintained for all rail cars.
- Shippers should eliminate using paper placards whenever possible.
- For Canadian shipments ensure that the emergency response plan is correct and updated for plant sites and transportation related releases.
- Ensure that the emergency response plan is exercised annually (drill).
- Shippers should show proper ERP number and associated telephone number on dangerous goods subject to the EDP requirements of transport Canada.
- Ensure that emergency contacts ans telephone numbers and plant site are correct and updated regularly.
- Key training programs should be implemented to:
- Ensure that all railroad personnel who enter a plant site are properly trained and/or receive orientation (especially for emergency actions).
- Establish, document, communicate and implement a company-wide tank car securement training program.
- Establish , document, train and implement a procedure for tank car customers to report poor securement, hard-to-operate valves and other fitting problems.
- Establish , document, train and implement company-wide preventative maintenance practices for tank cars.
- Ensure that all rail crossings within the plant site are properly marked with warning signs.
- Ensure rail lines are clear, switches are aligned properly, and car brakes are released before moving cars.
- Have plant personnel closely observe rail crews when they are operating within a plant site to assure plant and rail safety are being maintained.
- Have a documented routine process for providing feedback to the rail carrier.