AAR Circular Letter Summary – April 2023

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About AAR Circular Letters

Circular letter summaries are produced monthly by Greenbrier Management Services Group.

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AAR circular letters provide information of general applicability to the railroad industry, including proposed and final rules, revisions, standards and recommended practices, and calls for comments. These summaries provide the main points of circular letters issued in the prior month, as well as important implementation deadlines.

For access to the complete circular letter, please go to my.aar.org/circulars. Circular letters are a fee-based service provided by the AAR’s Transportation Technology Center Incorporated (TTCI). You may subscribe online at publications@aar.com or call 719.584.0538.

Implementation Circulars

C-14118
Implementation of Revisions to MSRP Section S, CASTING DETAILS, Specification M-201, Castings Steel, Regarding Changes to Section 4.0
Issued: April 4, 2023
Effective: April 4, 2023

On September 16, 2022, Circular Letter C-14019 was issued to solicit comments. Comments were received and considered by the CSTCC. Comments were addressed directly with the respondent and prompted no changes. Specification M-201 is now implemented and effective immediately.

C-14119
Implementation of a New Specification to MSRP, Section M, LOCOMOTIVES AND LOCOMOTIVE INTERCHANGE EQUIPMENT: Specification M-915 – QUALITY ASSURANCE REQUIREMENTS FOR LOCOMOTIVES AND LOCOMOTIVE COMPONENTS
Issued: April 7, 2023
Effective: April 7, 2023

Specification M-915 was developed by the Locomotive Committee (LC) at the request of and in cooperation with the Quality Assurance Committee’s (QAC) Audit Quality Task Force (AQTF). The intent is to clarify the harmonization of Section M requirements with the locomotive activity codes found in MSRP Section J, Specification M-1003. M-915 is appended to this circular and now implemented and effective immediately.

C- 14120
Implementation of Revisions to MSRP Section S, CASTING DETAILS, Specification M-212, Couplers and Yokes, Secondhand—Classification and Reconditioning Procedure
Issued: April 11, 2023
Effective:
April 11, 2023

On October 12, 2022, Circular Letter C-14034 was issued to solicit comments. Comments were received and considered by the CSTCC prompting the following change:

Figure C.48 was modified to correct the location of reference line B, and related wording of paragraph 6.1.5.3 was updated.

​​Additional editorial changes were made to Appendix F regarding applying for approval as a reconditioning facility. Specification M-212 is now implemented and effective immediately.

C- 14121
Implementation of Revisions to MSRP Section S, CASTING DETAILS, Specification M-214, Side Frames and Bolsters Used and Reconditioned – Classification and Repair Procedure
Issued:
April 11, 2023
Effective: April 11, 2023

On September 16, 2022, Circular Letter C-14020 was issued to solicit comments.  Comments were received and considered by the Coupling System and Truck Castings Committee (CSTCC).  In response to the comments received CSTCC updated the proposed images for the figure under paragraph 4.1.6.3.2. Additional editorial changes were made to Appendix A regarding applying for approval as a reconditioning facility. Specification M-214 is now implemented and effective immediately.

 

Call for Comment

CPC-1407
Solicitation of Comments on Proposed Revisions to MSRP Section C-III, Specification for Tank Cars (M-1002), Appendix B
Issued: April 10, 2023
Effective: 15 days for comment.

The Tank Car Committee (TCC) is requesting comments on the proposed revisions to Appendix B of AAR MSRP C-III, Specifications for Tank Cars (M-1002). Proposed changes pertain to facility certification requirements for activity codes A19, B78, C4A or C4M.

Present: N/A

Proposed: Appendix B 3.1.5.26  (new number to be determined)- A tank car facility with activity code A19, B78, C4A or C4M may have operations at more than one geographical location if;

  • Located within a 10 mile radius of the station stencil address.
  • Operating under a single station stencil
  • Using the same quality assurance program with a single production inspection and test plan for that activity.
  • Managed under a common organizational structure.
  • An auditor is able to observe all minimum demonstrations for that activity during a single audit.

C- 14122
Solicitation of Comments for Retirement of MSRP Section C, CAR CONSTRUCTION FUNDAMENTALS AND DETAILS, Standard S-203, Coupler, Height Adjustment
Issued: April 17, 2023
Effective: 30 days for comment.

The purpose of this circular letter is to solicit comments regarding retirement of Section C, Standard S-203, Coupler, Height Adjustment. S-203 provides direction on how to adjust coupler height. CSTCC and EEC reviewed S-203 and agree that these instructions are better suited to the AAR Field Manual. All relevant paragraphs of S-203 are now present in the AAR Field Manual or in Standard S-2044.  See the circular for bullet points detailing how S-203 material is now covered.

C- 14124
Solicitation of Comments, Revisions to Field Manual, Rules 1, 3 and 4, 4-Pressure Requirements
Issued: April 24, 2023
Effective: 30 days for comment.

At the April 2023 meeting of the Arbitration and Rules Committee, a proposal by the Brake Systems Committee (BSC) to revise Field Manual Rules 1, 3 and 4 to increase the rate of application of 4-pressure access plates and receivers, and to address inventory issues with 4-pressure test devices, was reviewed and approved.  See the circular for the entire text of the proposed revision.

C- 14133
Solicitation of Comments, Revisions to Office Manual, Rule 88.C.3.c, Minimum Mechanical Requirements Chart
Issued: April 25, 2023
Effective: 30 days for comment.

At the April 2023 meeting of the Arbitration and Rules Committee, a proposal by the Equipment Engineering Committee (EEC) to revise Office Manual Rule 88.C.3.c(1)(i) to require braking ration to be checked on all modifications was reviewed and approved.  See the circular for the entire text of the proposed revision.

C- 14132
Solicitation of Comments, Revisions to Office Manual, Rule 89, Equipment Alerts
Issued: April 25, 2023
Effective: 30 days for comment.

At the April 2023 meeting of the Arbitration and Rules Committee, a proposal to revise Office Manual Rule 89, Equipment Alerts was reviewed and approved.  The proposal includes the removal of the “Procedures for Issuing Equipment Alerts” as this is an outdated process.  If there is a concern with a specific set of cars the AAR should be notified per Rule 125 Equipment Advisory.  The AAR and the appropriate Technical Committee will review to determine if an Equipment Advisory is required. See the circular for the entire text of the proposed revision.

C- 14131
Solicitation of Comments, Revisions to Field Manual, Appendix B.C
Issued: April 25, 2023
Effective: 30 days for comment.

At the April 2023 meeting of the Arbitration and Rules Committee, a proposal by the Specially Equipped Freight Car Committee (SEFCC) to revise Appendix B.C, Certification Requirements, was reviewed and approved. See the circular for the entire text of the proposed revision.

C- 14130
Solicitation of Comments, Revisions to Field and Office Manuals, Appendix A, Definitions
Issued: April 25, 2023
Effective: 30 days for comment.

At the April 2023 meeting of the Arbitration and Rules Committee, a proposal as advanced by the Car Repair Billing Committee to revise Appendix A definitions of Repair Event and Standard Point Location Code, was reviewed and approved. See the circular for the entire text of the proposed revision.

C- 14129
Solicitation of Comments, Revisions to Field Manual, Rules 17, 18 and 59
Issued: April 25, 2023
Effective: 30 days for comment.

At the April 2023 meeting of the Arbitration and Rules Committee, a proposal by the Equipment Engineering Committee (EEC) to revise Rules 17, 18 and 59 was reviewed and approved. See the circular for the entire text of the proposed revision.

C- 14128
Solicitation of Comments, Revisions to Field Manual, Rules 37 and 46
Issued: April 25, 2023
Effective: 30 days for comment.

At the April 2023 meeting of the Arbitration and Rules Committee, a proposal by the WABL Committee to revise Rules 37 and 46 was reviewed and approved. See the circular for the entire text of the proposed revision.

C-14127
Solicitation of Comments, Revisions to Field Manual, Rule 37.A.1
Issued: April 25, 2023
Effective: 30 days for comment.

At the April 2023 meeting of the Arbitration and Rules Committee, a proposal by the WABL Committee to revise Rule 37 was reviewed and approved. See the circular for the entire text of the proposed revision.

C- 14126
Solicitation of Comments, Revisions to Field Manual, Rule 36.E.11
Issued: April 25, 2023
Effective: 30 days for comment.

At the April 2023 meeting of the Arbitration and Rules Committee, a proposal by the WABL Committee to revise Rule 36 was reviewed and approved. See the circular for the entire text of the proposed revision.

C- 14125
Solicitation of Comments, Revisions to Field Manual, Rule 15
Issued: April 25, 2023
Effective: 30 days for comment.

Solicitation of Comment Circular, C-14046, was issued on October 31, 2022, seeking industry feedback on proposed changes to Rule 15.  Job Code 2102 was not implemented in January 2023 due to the lack of a time standard.  The time standard is planned to be completed prior to July 1, 2023, therefore Job Code 2102 is proposed for inclusion in the July 1, 2023 update to the Field Manual. See the circular for the entire text of the proposed revision.

 

Notice of Circulars

C-14123
Save the Date – Announcing the 2024 AAR’s 36th Quality Assurance Auditor and Industry Conference
Issued: April 21, 2023
Effective: April 21, 2023

The Association of American Railroads (AAR) Quality Assurance Committee (QAC) is pleased to announce the 36th Annual AAR Quality Assurance Auditor & Industry Conference will take place February 27th – 29th, 2024 in Phoenix, Arizona​. The AAR QAC seeks to improve the conference based on recommendations from QAC members, AAR Auditors, and previous conference attendees.  In 2024, a new series of workshops will be available.  The QAC’s mission includes ensuring that AAR auditors are well-trained, with the goal of improving audit consistency, auditing practices, and knowledge of the M-1003 standard.

 

Upcoming Event

NARS Annual Meeting
May 24 – 26, 2023

Greenbrier is a proud sponsor at the NARS Annual Meeting in Chicago. Featured speaker: Rick Galvan, Senior Vice President, Greenbrier Rail Services.

 

Greenbrier’s Regulatory Services Group

Peace of mind for your business.

The Regulatory Management Group, led by James Rader, provides regulatory, engineering, process consulting and advocacy support to the railcar repair industry and the petrochemical rail shipper community.

  • ASNT Level III Subscription Services
  • DOT Compliance Assessments (Corporate and Plant)
  • DOT Hazardous Materials Training (Corporate and Plant)
  • Expert Witness Services in Rail-Related Litigation
  • Federal Government Claims Mitigation (e.g. FRA and PHMSA)
  • Nondestructive Testing Programs
  • Quality Assurance Program Development
  • Regulatory Counsel and Policy Advocacy
  • Railcar Repair Management (Design Review, Drawings, Engineering and AAR Approval Administration)
  • Tank Car Reliability and Maintenance Programs (49 CFR Subpart F of Part 180)
  • Tank Car Maintenance Data Collection and Reliability Performance Analysis
  • Welding Program Development

For inquiries about these summaries or any of our services, please reach out to: regulatoryservices@gbrx.com

 

About Greenbrier Management Services (GMS)

Greenbrier Management Services (GMS) is North America’s most comprehensive railcar management solutions provider. GMS manages nearly 400,000 railcars and has invested over 20 years in developing technology, processes, and people to provide the best railcar management products and services in the industry. GMS is powered by proprietary software and the best subject matter experts in the railcar business.

 

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Combined, these two vitally important capabilities are able to deliver world-class solutions to every type of customer, from Class I railroads, lessors and industrial shippers to financial investors. GMS brings broad expertise to cover nearly any railcar management need that customers may have and its integrated solutions and reporting can be customized for any customer function or management need.