About AAR Circular Letters
Circular letter summaries are produced monthly by Greenbrier Management Services Group.
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-14111
Notice of Implementation of Circular No. 42-P, General Rules Governing the Loading of Carload Shipments of Commodities in Closed Car (DP&FC)
Issued: March 9, 2023
Effective: March 9, 2023
The AAR’s Damage Prevention & Freight Claim Committee (DP&FC) has approved changes to Circular No. 42-P, General Rules Governing the Loading of Carload Shipments of Commodities in Closed Car (DP&FC). This revision to Circular 42, General Rules Governing the Loading of Carload Shipments of Commodities in Closed Car (DP&FC) are now implemented and effective immediately.
Call for Comment
C-14110
Solicitation of Comments for Revisions to MSRP Section H-II, ROLLER BEARING MANUAL, Standard S-723, Inner Ring Inspection. Additional inspection requirements.
Issued: March 8, 2023
Effective: 30 days for comment.
The proposed inspection of the inner ring in both directions has a maximum one-year industry cost of $4.35 million and 15-year net present cost of $35.15 million. Both of these costs are below the cost benefit analysis requirement thresholds prescribed in AAR Standard S-050. Changes are highlighted with change bars in the draft of Standard S-723 (attached to the circular).
C-14113
Solicitation of Comments for Revisions to MSRP Section C, CAR CONSTRUCTION FUNDAMENTALS AND DETAILS, Standard S-910 and Specifications M-800 and M-801, edits relative to marking of autoracks and certain hopper cars
Issued: March 14, 2023
Effective: 30 days for comment.
This circular has been issued to solicit comments for the following revisions:
- Standard S-910 Marking of Freight Cars, paragraph 16.6.1.2: Correction to the description of Deck Clearance Height on autoracks.
- Specification M-800 Hopper Car, Covered – for Transport of Oxidizing Commodities: Guidance for marking was previously moved into standard S-910.
- Specification M-801 Hopper Car, Covered – Pressure Differential: Guidance for marking was previously moved into standard S-910.
Changes are indicated with lined-out text for omitted passages, and with call outs for inserted text (attached to the circular).
C-14114
Solicitation of Comments for Revisions to MSRP Section B, FREIGHT CAR DRAFT COMPONENTS, Specification M-921D Cushioning Devices, End-of-Car, Motor-Vehicle-Carrying. Addition of New Requirements
Issued: March 15, 2023
Effective: 30 days for comment.
New requirements have been added to the specification to fully document the performance and physical condition of devices after service testing. The new requirements are listed in the following paragraphs:
- 1.4 Post-Service Testing
- 1.4.1 Preload Effectiveness Test
- 1.4.2 Restoring Performance Test
- 1.4.3 Final Teardown Inspection
The draft of the proposed revision is attached to the circular. In addition to the changes listed above, the entire specification has been fully edited for clarity.
C-14116
Solicitation of Comments for revisions to MSRP E BRAKES AND BRAKE EQUIPMENT, S-4027, Automated Single Car Test Equipment, Conventional Brake Equipment—Design and Performance Requirements. Data validation enhancements
Issued: March 15, 2023
Effective: 30 days for comment.
The proposed changes do not modify the test process or any technical requirements of the codified portion of the standard, which is incorporated by reference in 49 CFR 232.305(f)(1)(ii). However, the 2018 version of this standard is referenced by the CFR, and the CFR will need to be updated (as outlined in 1 CFR 51.11). This process is procedural and is not expected to impact the implementation of S-4027.
Changes are highlighted with change bars in the draft of S-4027. The referenced Federal Regulations are also attached to the circular.
Notice of Circulars
C-14109
Informational Circular, Car Repair Facility Labor Rate – Effective April 1, 2023
Issued: March 6, 2023
Effective: March 6, 2023
The Car Repair Facility Labor Rate, effective April 1, 2023, is $187.57, an increase of $0.57 (or 0.30%) from the labor rate calculated for January 1, 2023.This will be reflected in the April 1, 2023 release of the AAR Office Manual.
C-1411
Informational Circular – MSRP Section N, Specification M-951, Portable Bridge Plates for Multi-Level Auto Rack Cars
Issued: March 9, 2023
Effective: March 9, 2023
This is an informational circular to allow the industry time to prepare for changes to MSRP, Section N, M-951. The Specially Equipped Freight Car Committee is implementing revisions to Specification M-951 that will be effective on 01/01/2025. This implementation will sunset any low-capacity bridge plate, which is a bridge plate manufactured prior to 2005. The addition with be to Specification M-951, 8.5 Any bridge plate manufactured prior to 2005 will no longer be approved for vehicle loading or unloading.
C-14115
Reminder: 2023 AAR M-1003 Quality Assurance Auditor Training Class Schedule
Issued: March 15, 2023
Effective: March 15, 2023
The Association of American Railroads (AAR) Quality Assurance Committee (QAC) has updated the schedule (attached to the circular) for the 2023 AAR M-1003 Quality Assurance Training classes.
C-14117
Informational Circular, Canadian Car Repair Facility Labor Rate – Effective April 1, 2023
Issued: March 16, 2023
Effective: March 16, 2023
The Canadian Car Repair Billing Labor Rate calculation for April 1, 2023 is $242.94 CAD, an increase of $3.57 CAD from the calculation for January 1, 2023.
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.
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.