DOT 111 Non-Jacketed CPC-1232 Ethanol Cars

At the April AAR TCC meeting, the FRA reminded everyone of certain Class 3 flammable liquid commodities (such as ethanol) and the phase out of DOT 111 non-jacketed CPC-1232 tank cars by July 1, 2023. PHMSA defined ethanol as: UN1170, NA1987, UN1987, or UN3475.

No loaded tank car may be offered into transportation and the FRA will not grant an OTMA for a loaded tank car. Residue tank cars will only be allowed to move with an OTMA from the FRA or Temporary Certificate from TC.

For any additional information or help with your regulatory needs, reach out to AllTranstek today!

Document Retention

49 CFR §180.517 covers reporting and record retention requirements. Tank car owners are required to maintain certain documents (such as drawings, COCs, qualification paperwork, etc) as specified in AAR CIII Chapter 1 paragraph 1.3.15 which specifies paragraph 1.6. The documents and retention periods are listed in a table under paragraph 1.6.4. These documents must be maintained by the car owner and transferred to the new car owner upon sale.

AllTranstek can help you review your car documentation to verify compliance with the regulations for your existing fleet or future acquisitions.

New Wheels vs. Reconditioned Wheels

Have you ever noticed that when a Railroad (RR) repairs your owned cars most of the time they apply new wheels? One reason is that new wheels are easier to get and the RRs can charge more. But the RRs may know something you don’t; reconditioned wheels are not only less expensive, but they tend to last longer than a new wheel. By looking at RR provided BRC repair data you may be surprised to see that you do indeed tend to get more miles per 16th inches of wear from a reconditioned wheel vs a new wheel. Some shippers have PM programs where they replace wheels before they are condemned with reconditioned wheels vs letting the RR replace with new wheels. Other shippers have set up bi-lateral agreements with individual RRs in which they agree to pay more than the AAR rates in return for getting reconditioned wheels applied to their cars. Volume is everything when it comes to wheel prices and for smaller fleets it might not make any sense to consider any of these arrangements. That said, wheels are almost always a car owner’s number one maintenance expense.

Contact AllTranstek to learn suggestions on reducing your costs.