AAR Circular Letter Summary – June 2022

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About AAR Circular Letters

Circular letter summaries are produced monthly by Greenbrier’s Regulatory Management team, a division of 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

CPC-1396
Implementation of Revisions to MSRP Section C-III, Specification for Tank Cars (M-1002), Chapter 1 and Appendix Z
Issued: June 16, 2022
Effective: June 16, 2022

The circular presents final action on revisions to the AAR Manual of Standards and Recommended Practices (MSRP), Section C, Part III, Specifications for Tank Cars (M-1002). All revisions are identified by change bars in the margins of the Chapter 1 and Appendix Z (attached to circular).

Revisions include the addition of two new terms to Chapter 1 and the addition of New Appendix Z:

  • Noncompliance: An adverse audit finding in which the facility’s quality assurance program does not meet specified requirements.
  • Nonconformance: An activity that does not meet the applicable standards, specifications, recommended practices, rules, codes, regulations, and/or contractual requirements.
  • Appendix Z specifies the use of ANSI Z1.4 by a tank car facility when requested by the TCC.

 

CPC-1395
Implementation of Revisions to MSRP Section C-III, Specification for Tank Cars (M-1002), Appendix B
Issued: June 16, 2022
Effective: June 16, 2022

The circular presents final action on revisions to AAR Manual of Standards and Recommended Practices (MSRP), Section C, Part III, Specifications for Tank Cars (M-1002). All revisions are identified by change bars in the margins of Appendix B (attached to circular).

Summary of Final Revisions:

  • Specifies the test fixture demonstration option for service equipment category H under activity code C4m and C5
  • Implementation of QA program requirements as specified in CPC-1389 whereby TCC adopted M-1003 requirements from the 2019 version to remain consistent with the scope and objective of M-1002 Appendix B. Per TCC, these were existing QA program requirements therefore a CPC was not issued for solicitation of industry comment.

 

C-13997
July 2022 Field and Office Manuals, Summary of Comments, and Implementation Details
Issued: June 21, 2022
Effective: June 21, 2022.

In April and May 2022, several Circular Letters soliciting comments to the proposed rule changes were issued. In addition, several letters were issued that advised of approved changes that would become effective on July 1, 2022. The circular summarizes those letters seeking industry comment or receiving comment, an indication of comments received (if any), consideration and implementation details. Unless otherwise noted, the rule changes are for the Field Manual.

 

Call for Comment

CPC-1397
Solicitation of Comments on Proposed Revisions to MSRP Section C-III, Specification for Tank Cars (M-1002), Appendix B Paragraph 2.0
Issued: June 17, 2022
Effective: 30 days for comment.

The Tank Car Committee published circular CPC-1395 to maintain continuity of the activity code certification requirements as presented in CPC-1389. This did not change the requirements for certification of activity codes required by tank car facilities. However, as there were changes made to Appendix B paragraph 2.0 of M-1002 the TCC will consider comments to that paragraph.

At this time, each M-1003 facility with tank car related activity codes must include the 2019 requirements of M-1003 in their quality assurance program, which remains in effect until June 30, 2022. At which time Appendix B as presented in CPC-1395 will be in effect. Comments from industry will be considered by the Tank Car Committee to determine if any modifications are necessary to M-1002 Appendix paragraph 2.0.

Questions should be directed to Kenneth Dorsey, Executive Director of Tank Car Safety via email at: kdorsey@aar.org.

 

Notice of Circulars

C-13994
Announcing the 2022 NARMO Webinar Series – Registration Open NowC-13994
Issued: June 6, 2022
Effective: Seminar will take place in July 2022.

The AAR is presenting a series of webinar sessions aimed at providing educational content typically offered at the North American Mechanical Operations (NARMO) Seminar. The webinars are free to attend and open to all. The target audience of mechanical repair and car repair billing personnel especially encouraged to participate.

Topics include:

  • AAR Interchange Rules Updates Panel
  • Rail & Record Type 6 Update
  • Wreck Repair Billing and Joint Inspection Certificate (JIC) Preparation and Standardization
  • CRB 101/Navigating the Field and Office Manual

The circular contains the schedule and links for registration.

 

C-13996
Informational Circular, Canadian Car Repair Facility Labor Rate – Effective July 1, 2022
Issued: June 23, 2022
Effective: July 1, 2022

The Canadian Car Repair Facility Labor Rate, effective July 1, 2022 is $228.54 CAD.

 

C-13995
Informational Circular, Car Repair Facility Labor Rate – Effective July 1, 2022
Issued: June 23, 2022
Effective: July 1, 2022

The Car Repair Facility Labor Rate, effective July 1, 2022 is $149.27.

 

Upcoming Event

MARS Summer Meeting
July 18–19, 2022

Joining us at the next MARS meeting at the Grand Geneva Resort in Lake Geneva, WI.

 

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.

 

COMPREHENSIVE. INTEGRATED. VALUE.

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.