About AAR Circular Letters
Circular letter summaries are produced monthly by Greenbrier’s Regulatory Management team, a division of 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-13839
IMPLEMENTED. AAR Manual of Standards and Recommended Practices (MSRP), Section K-V Electronics Environmental Requirements and Systems Management, Standard S-9452A.V2.0
Issued: August 16, 2021
Effective: August 16, 2021
Standard S-9452A.V2.0 (attached to the circular) details the wayside interface unit (WIU) asset-specific data dictionary for ITC systems management (ITCSM). The standard will be incorporated into the next issue of the MSRP, Section K-V. In the interim, insert the Circular into your copy of the MSRP Section K-V and be governed accordingly.
C-13842
IMPLEMENTED. AAR Manual of Standards and Recommended Practices (MSRP), Section K-V Electronics Environmental Requirements and Systems Management, Standard RP-9457.V2.0
Issued: August 17, 2021
Effective: August 17, 2021
RP-9457.V2.0 (attached to the circular) provides a recommended practice for testing the PTC system. The MTS establishes a common approach and terminology for testing PTC systems for use among railroads and their vendors. RP-9457.V2.0 will be incorporated into the next issue of the MSRP, Section K-V Electronics Environmental Requirements and Systems Management. In the interim, insert the Circular into your copy of the MSRP Section K-V and be governed accordingly.
C-13841
IMPLEMENTED. AAR Manual of Standards and Recommended Practices (MSRP), Section K-I Railway Electronics Systems Architecture and Concept of Operations, Standard S-9076.V1.0
Issued: August 17, 2021
Effective: August 17, 2021
Standard S-9076.V1.0 describes the Interoperable Train Control Systems Management (ITCSM) Gateway requirements for processing interoperable ISMP messages. It will be incorporated in the next issue of MSRP, Section K-I Railway Electronics Systems Architecture and Concept of Operations. In the interim, insert the Circular into your copy of the MSRP Section K-I and be governed accordingly.
C-13840
IMPLEMENTED. AAR Manual of Standards and Recommended Practices (MSRP), Section K-V Electronics Environmental Requirements and Systems Management, Standard S-9451A.V2.0
Issued: August 17, 2021
Effective: August 17, 2021
Standard S-9451A.V2.0 details the WIU asset-specific requirements for ITC systems management (ITCSM). It will be incorporated into the next issue of MSRP, Section K-V. In the interim, insert the Circular into your copy of the MSRP Section K-V and be governed accordingly.
Call for Comment
C-13838
Solicitation for Comments for Proposed Revisions to AAR MSRP Section J, Specification for Quality Assurance M-1003
Issued: August 13, 2021
Effective: 30 days for comment.
A PDF of the proposal is attached to the circular. Changes include:
- The revision maintains the current 24 clause structure of chapter 2.
- Terms which are included in the definitions (section 1.3) are italicized throughout the standard for ease of reference.
- Several requirements which had previously been listed in views and interpretations (appendix C) are now incorporated in chapter 2.
- Views and interpretations will be removed from M-1003 and added to the AAR QAC frequently asked questions web page. This will allow for more frequent update by the AAR QAC. The revision maintains the current 24 clause structure of chapter 2.
- Terms which are included in the definitions (section 1.3) are italicized throughout the standard for ease of reference.
- Several requirements which had previously been listed in views and interpretations (appendix C) are now incorporated in chapter 2.
- Views and interpretations will be removed from M-1003 and added to the AAR QAC frequently asked questions web page. This will allow for more frequent update by the AAR QAC.
The planned release date for this revision is October 2021. AAR Accredited Quality Assurance Auditors will begin utilizing the revision upon release. However, auditors will not document a nonconformance finding under the new requirements until March 2022, allotting six months for M-1003 certified facility’s Quality Assurance Programs to be revised accordingly.
C-13845
Solicitation of Comments for Proposed Revisions to MSRP – Section T-Interoperable Fuel Tenders for Locomotives, Specification M-1004 – Specification for Fuel Tenders
Issued: August 25, 2021
Effective: 30 days for comment.
The proposal (attached to the circular) incorporates changes to the M-1004 specification to accommodate revised testing requirements as outlined in Chapter 11. The M-1004 Specification and supporting standards allow new fuel tenders to be qualified for unrestricted interchange in freight service. The AAR documents identify the tender’s structural design requirements, operating performance, crashworthiness, and fuel interfaces needed to supply natural gas to dual-fuel locomotives, and interfaces needed to load the tender with fuel.
C-13846
Solicitation of Comments – Proposed Revisions to MSRP, Section M, LOCOMOTIVES AND LOCOMOTIVE INTERCHANGE EQUIPMENT: Standard S-5513 – LOCOMOTIVE ALERTER REQUIREMENTS
Issued: August 26, 2021
Effective: 30 days for comment.
The proposal is attached to the circular.
Notice of Circulars
C-13837
Informational Circular, Authentication and Validation of Automated Single Car Air Brake Tests
Issued: August 2, 2021
Effective: August 2, 2021
Recognizing the benefit of an Automated Single Car Test (ASCT) over a manual test, the FRA has extended the interval for cars that receive a Single Car Test (SCT) with an Automated Single Car Test Device (ASCTD). The ABT Due Date (Repair Track) reflected in UMLER will be based on the type of Air Brake Test (ABT) performed.
When on a shop or repair track an ABT is required if the ABT Due Date (Repair Track) in UMLER is due or overdue. This field is populated based on the prior test date and device type as identified below:
- A manual single car ABT performed will set the ABT Due Date (Repair Track) to 12 months from the date of the test
- An automated single car ABT performed will set the ABT Due Date (Repair Track) to 24 months from the date of test
- A 4-pressure single car ABT performed will set the ABT Due Date (Repair Track) to 48 months from the date of the test
As part of FRA’s rulemaking, AAR S-486 and AAR S-4027 were incorporated into the federal regulations. Adherence to S-486 and S-4027 is required to satisfactorily complete the tests, and to report the car as having received a single car test. The ASCTDs are required to capture pertinent information as specified in S-4027. In lieu of stenciling, FRA allows the use of secure “electronic or automated tracking system” that is capable of being reviewed and monitored by FRA at any time to ensure the integrity of the system. Recent FRA audits have identified errors for cars that were indicated as having passed an automated test but lacked validation.
For compliance, attention should be directed to the following:
- Accurate operator ID which can be traced to training records.
- Accurate car identification, including car letters and numbers.
- Correct identification of brake equipment being tested.
As a result of recent audits of ASCT records, particularly items 1 and 4 above, an Equipment Advisory will identify equipment having incomplete ASCT test records. The affected equipment will be required to receive a properly verified ASCT.
CPC-1384
Recommended Railroad Operating Practices for Transportation of Hazardous Materials (OT55R)
Issued: August 16, 2021
Effective: August 16, 2021
Final Notice: Appendix 3 (the list of Environmentally Sensitive Chemicals) has been added back to OT-55. The Sample Request for Hazardous Materials Commodity Flow Information will now be in Appendix 4. These are the only changes from OT-55-Q. AAR Circular No. OT-55-R (attached to the circular) becomes effective April 30, 2021 and supersedes OT-55-Q.
C-13843
Updated Schedule for 2021 AAR M-1003 Basic and Advanced Auditor Training Classes
Issued: August 18, 2021
Effective: Schedule included in the circular.
The Association of American Railroads (AAR) Quality Assurance Committee (QAC) has finalized the schedule for the remaining 2021 AAR M-1003 Quality Assurance Training classes. The Basic Auditor Training classes will remain in Webinar format throughout 2021, but the Advanced Auditor Training classes will be in-person, on-site training classes. Per AAR policy, in-person classes are only open to those who are fully vaccinated for COVID (at least two weeks past final vaccination). Proof of vaccination status will not be required. The full schedule and course description is included in the circular.
CPC-1385
Non-Compliance with the PRV Registration System
Issued: August 18, 2021
Effective: August 18, 2021
The purpose of this letter is to remind industry of the how the PRV registration system works. Facilities are attempting to register PRVs without approved PRV bar code labels, facilities not authorized to register PRVs are attempting to register PRVs, and facilities not authorized to associate a PRV to a tank car are attempting to do so.
Registration of a PRV is only permitted by a tank car facility certified for activity codes C4 (C4a/C4m) and C5 and only where a C4 or C5 facility has an AAR-approved PRV bar code label. Furthermore, a PRV can only be associated with a tank car if the facility is certified for activity codes C6, C6i, or C6r.
Each C4 (C4a/C4m), and/or C5 certified facility actively registering PRV’s without PRV bar code label approval must stop doing so immediately until authorization to resume registration in accordance with paragraph 3.0 of S-920 has been received from AAR. Tank car facilities failing to comply with M-1002 and S-920 may be audited to determine compliance per M-1002, Appendix B, paragraph 4.7.1.2. Tank cars not in compliance with S-920 are not compliant in interchange.
Note to tank car owners: AAR issues notification emails with attached acceptance letters to the certified facilities once their PRV bar code label is accepted by the AAR.
C-13844
Save the Date – Announcing the 2022 AAR’s 34th Quality Assurance Auditor and Industry Conference
Issued: August 19, 2021
Effective: April 12-14, 2022.
The Association of American Railroads (AAR) Quality Assurance Committee (QAC) has scheduled the Annual AAR Quality Assurance Auditor and Industry Conference for April 12-14, 2022, in Fort Worth, Texas. Additional information regarding registration is forthcoming. A tentative schedule and conference topics are included in the circular.
Upcoming Events
SWARS 2021 Fall Meeting
September 29-30, 2021
GBX is a proud sponsor at the SWARS meeting on September 29 and 30 in Fort Worth, Texas.
Greenbrier’s response to COVID-19
As this challenging time continues, Greenbrier would like to provide an update on operations and our continued dedication to our customers, employees, and communities. As rail workers and contractors are designated “Essential Critical Infrastructure Workers”, Greenbrier’s manufacturing and repair facilities are fully operational. Our office teams are available as well, though most are working remotely. We encourage you to contact your Greenbrier representative if you have any questions or concerns—we are here for you.
For more information, visit our webpage that details Greenbrier’s response to COVID-19.
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.