If you are shipping hazardous materials in a tank car, U.S. Department of Transportation (DOT) hazardous materials regulations (HMRs) require that you perform periodic inspections and external visual inspections before the shipment takes off. But, what exactly does that mean? Today we’ll offer some tips for inspecting hazardous materials tank cars, and tomorrow we’ll take a look at a recent DOT clarification of what it means to be an “offeror” of hazardous materials in transportation.
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In a recent query concerning inspecting tank cars carrying hazardous materials, DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) officials gave what seems to be a common response of “like, maybe, whatever.” Let’s take a look at this recent response and then some solid tips for inspecting hazardous materials tank cars.
Do You Have to Inspect Things Like Couplers?
A hazmat shipper recently asked PHMSA if shippers of tank cars containing hazardous materials are required to inspect the tank car’s “running gear components (wheels, axles, brake system components, bolsters, side frames, etc.)” and all other tank car fittings like “sill steps [and] grab irons couplers” for defects before offering the tank car for transportation.
In a classic “regspeak” response, PHMSA officials said that generally, no, the HMR related to railroad safety appliance standards do not require you to inspect a tank car’s running gear components or safety appliances for defects before shipping. However, general shipping regulations for tank cars prohibit shipping hazardous materials in a tank car unless you perform an external visual inspection. There are specific requirements to examine, among other things, a tank car’s coupler vertical restraint system for defects that would make the tank car unsafe for transportation.
10 Tips for Inspecting Tank Cars
Before you send a tank car containing hazardous materials off, you must perform an external visual inspection. Here are ten tips that will help you determine if your tank car is “transportation ready.”
Tip 1. Check the tank shell and heads for such conditions as (but not limited to) abrasion, corrosion, cracks, dents, distortions, and defects in welds. You can disregard this tip if insulation or some sort of thermal protection system would make an inspection impossible.
Tip 2. Inspect the piping, valves, fittings, and gaskets for corrosion, damage, or any other condition that would make the tank car unsafe.
Tip 3. Make sure there are no missing or loose nuts or bolts.
Tip 4. Ensure that all closures and fastenings on the tank car are secure. Tighten them in place by using a tool such as a bar or wrench.
Tip 5. Inspect protective housings, and make sure they are secured.
Tip 6. Check the pressure relief device for corrosion or other damage. If the tank car has a nonreclosing pressure relief device, make sure to carefully inspect the rupture disc. To ensure the integrity of a rupture disc, inspect each telltale indicator after filling and before transportation.
Tip 7. Inspect the external thermal protection system, tank-head puncture resistance system, coupler vertical restraint system, and bottom discontinuity protection for any conditions that would make the tank car unsafe.
Tip 8. Make sure the required markings on the tank car are legible.
Tip 9. Check the periodic inspection date markings to ensure that the inspection and test intervals are within the prescribed intervals.
Tip 10. Make sure that the closures on the tank cars are in tool-tight condition so that there will be no hazmat release under normal transportation conditions. DOT inspectors will assume that you did not perform a proper visual inspection if the closures are not tool-tight.