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-13715
Implementation of Revisions to MSRP Section T INTEROPERABLE FUEL TENDERS FOR LOCOMOTIVES, New Standards S-5031 and S-5032 for Tender Fill Electrical Cables
Issued: December 1, 2020
Effective: December 1, 2020
Standards S-5031 and S-5032, attached to the circular, are now implemented and effective immediately. This modification will be incorporated in the next issue of the Manual of Standards and Recommended Practices, Section T. Please update your library and be governed accordingly.
C-13714
Implementation of Revisions to MSRP Section T INTEROPERABLE FUEL TENDERS FOR LOCOMOTIVES, Specification M-1004, Specification for Fuel Tenders, and Supporting New Standards S-5028, S-5029 and S-5030
Issued: December 1, 2020
Effective: December 1, 2020
Specification M-1004 and new Standards S-5028, S-5029, and S-5030, attached to the circular, are now implemented and effective immediately. This modification will be incorporated in the next issue of the Manual of Standards and Recommended Practices, Section T. Please update your library and be governed accordingly.
C-13726
IMPLEMENTED. AAR Manual of Standards and Recommended Practices (MSRP), Section K-I Railway Electronics Systems Architecture and Concept of Operations, Standard S-9081.V1.0
Issued: December 18, 2020
Effective: December 18, 2020
Standard S-9081.V1.0 contains the format and establishes some of the data contents of the Train Sheet Transaction Set (EDI 161), Applicable Advise – Train Sheet (EDI 824) and Train Consist Transaction Set (EDI 418J) for use within the context of the Electronic Data Interchange (EDI) environment. These transaction sets can be used to allow railroads to exchange train information and ensure that the crews operating equipment on the other railroads are aware of current operating conditions.
Standard S-9081.V1.0 was Adopted in 2020 and is attached to this Circular in PDF format. It will be incorporated in the next issue of the MSRP, Section K-I Railway Electronics Systems Architecture and Concept of Operations. In the interim, please insert the Circular in your copy of the MSRP Section K-I and be governed accordingly.
Call for Comment
C-13716
Solicitation of Comments: Revisions to MSRP Section F, Sensors, Standard S-6101 – Detector Calibration & Validation Requirements
Issued: December 3, 2020
Effective: 30 days for comment
The proposed additions to this standard include:
- 0 Acoustic Bearing Detector (ABD) Fault Descriptor Validation
- 0 ABD Site Validation
- 0 ABD Software Version Update Process
- 0 ABD Hardware Version Update Process
The proposed additions to S-6101 are attached to the circular. Please submit any comments to gdeibler@aar.org and include an identifiable reference such as “Circular comment” in the subject line.
C-13717
Solicitation of Comments, Revisions to Office Manual, Rule 88.C
Issued: December 4, 2020
Effective: 30 days for comment
The following section has been proposed for Office Manual Rule 88.C.1.d(2)(g):and pertains to replacing the entire car body (which may or may not include replacing the underframe) and includes:
- The built date and EIN of the modified car in Umler will be the same as the original car
- The car mark and number that was stamped onto the original sill must be stamped onto the new car body sill.
- The facility conducting the modification must have approval under AAR Standard S-2034.
- Updating of the safety appliances per item (17) of the minimum mechanical requirements chart is applicable.
- The entire original car body must be scrapped.
The revision to Office Manual Rule 88.C.3.c(17) pertains to Safety Appliances and updates the modify code from “No Change Required” to “When Applicable.”
The targeted implementation date via circular is early 2021.
C-13718
DRAFT Standard S-9081.V1.0-Positive Train Control(PTC)-Interoperable Train Control(ITC)-Electronic Data Interchange(EDI) Rules Governing the Use of EDI 161, EDI 824 & EDI 418J, is available for review and comment. In support of AAR’s MSRP, Section K-I.
Issued: December 5, 2020
Effective: 7 days for comment
The document contains the format and establishes some of the data contents of the Train Sheet Transaction Set (EDI 161), Applicable Advise – Train Sheet (EDI 824) and Train Consist Transaction set (EDI 418J) for use within the context of the Electronic Data Interchange (EDI) environment. These transaction sets can be used to allow railroads to exchange train information and ensure that the crews operating equipment on the other railroads are aware of current operating conditions.
The DRAFT document and the Comment Form can be found at: https://communities.railinc.com/sites/aar/aarptcresc/resclibrary/Public%20Documents/Posted%20For%20Industry%20Comment/S-9081%20V%201.0%20%20PTC%20ITC%20EDI%20Rules
C-13719
Solicitation of Comments: Additions to MSRP Section F, SENSORS | S-920 AAR Component Identification Bar Code Standard: Tank Car Service Equipment
Issued: December 10, 2020
Effective: 30 days for comment
AAR’s Tank Car Committee (TCC) has approved proposed modifications to include of tank car pressure relief valves into the component registry. The draft of Standard S-920 is attached to the circular (CPC-1373 and AAR circular C-13705). Please submit comments to mforister@aar.org and include the circular number and the word “Comments” in the subject line.
CPC-1374
Solicitation of Comments on Proposed Revisions to MSRP Section C-III, Specification for Tank Cars (M-1002), Chapter 1 and Appendix T (Docket T88.1-93)
Issued: December 10, 2020
Effective: 37 days for comment (5:00PM eastern Saturday January 16, 2021)
the Evaluation and Use of Nondestructive Evaluation Techniques (Appendix T):
- New definition for NDI to align with the use of the term in Appendix T.
- Revised definitions of Nondestructive testing (NDT) and NDT Level III to support terms in Appendix T.
The following revisions (attached to the circular) are proposed for appendix T:
- Specifies NDT Level III must be certified by the American Society for Nondestructive Testing (ASNT) or the Canadian General Standards Board (CGSB).
- Adds Hydrostatic Testing as an NDT technique.
- Adds Electromagnetic Testing (ET) as an NDT method.
- Revised the Automated Ultrasonic Testing NDT technique.
- Revised Visual Inspection (VT) NDT method.
To facilitate the handling of industry comments, AAR requires Exhibit PC-1 ver. 3.0 form (attached to the circular) to be completely filled out and submitted to mforister@aar.org.
CPC-1373
Solicitation of Comments on Proposed Revisions to MSRP Section C-III, Specification for Tank Cars (M-1002), Chapter 1, Appendix A, and Appendix D (Docket T100.22.1)
Issued: December 10, 2020
Effective: 37 days for comment (5:00PM eastern Saturday January 16, 2021)
The AAR Tank Car Committee has approved to move forward with component tracking of tank car service equipment, starting with pressure relief valves.
The following revisions (attached to the circular) are proposed for Chapter 1 and pertain to Service Equipment Component Tracking PRV:
- New definitions added to support component tracking of tank car service equipment.
- Identifies who is responsible for identification, registration, and association of component tracking of tank car service equipment.
The following revisions (attached to the circular) are proposed for Appendix A
- Standardizes the marking/identification requirements for tank car service equipment to align with component tracking registration.
- Establishes the effective date of April 1, 2021 for component tracking of pressure relief valves.
The following revisions (attached to the circular) are proposed for Appendix D
- Specifies when and how to associate tank car service equipment to the tank car.
- Removes the certificate of test form requirements for pressure relief valves since this information is now contained within the component ID.
The following revisions (attached to the circular) are proposed for AAR MSRP Section F, Standard S-920
- This CPC is being issued in concert with AAR circular letter C-13719 which is soliciting comment for adding pressure relief valves as a new section and appendix to S-920.
The following revisions (attached to the circular) are proposed for AAR Field and Office Manuals
- C-13705 is being issued in concert with this CPC which is soliciting comment for adding pressure relief valve component tracking. Please Note: the proposed implementation date is April 1, 2021 not January 1, 2021.
To facilitate the handling of industry comments, AAR requires Exhibit PC-1 ver. 3.0 form (attached to the circular) to be completely filled out and submitted to mforister@aar.org.
C-13725
DRAFT S-9370.V1.0 – Interoperable Event and Status Service is available for review and comment. In support of AAR’s MSRP, Section K-IV, Office Architecture and Railroad Electronics Messaging.
Issued: December 17, 2020
Effective: 15 days for comment
This document contains interoperable requirements for various “Event/Status,” “Requests,” and contains valid values for Subscription Flag field of the Subscription Request/Response messages.
Comments regarding the DRAFT may be submitted by using the Comment Form found on the SharePoint site and emailing the completed form to submitcomment@aar.org. The DRAFT document and Comment Form can be found at:
C-13724
DRAFT Standard S-9382.V1.0 – Interoperable Asset Access Service, is available for review and comment. In support of AAR’s MSRP, Section K-IV, Office Architecture and Railroad Electronics Messaging.
Issued: December 17, 2020
Effective: 30 days for comment
This document contains interoperable requirements for Asset Lookup & Asset Access and also includes the behavior requirements for these messages.
Comments regarding the DRAFT may be submitted by using the Comment Form found on the SharePoint site and emailing the completed form to submitcomment@aar.org. The DRAFT document and Comment Form can be found at: https://communities.railinc.com/sites/aar/aarptcresc/resclibrary/Public%20Documents/Posted%20For%20Industry%20Comment/S-9382%20V1.0%20Interoperable%20Asset%20Access%20Service
Notice of Circulars
C-13713
Informational Circular, Revisions to CRB Data Exchange Error Code Z8
Issued: December 1, 2020
Effective: December 1, 2020
End-of-car cushion units and tank car pressure relief valves will become AAR required components in 2021 (C-13586 and C-13705). As such, CID data for these components will be allowed to pass through the Car Repair Billing (CRB) Data Exchange, and updates to error code Z8 are required to allow new values ‘GQ’ and ‘QM’. The entirety of the revision to error code Z8 is included in the circular. The update will be implemented after the January 2021 run of the CRB Data Exchange and will be included in the January 2021 revision of the CRB Procedures Manual.
C-13721
Informational Circular, Canadian Car Repair Facility Labor Rate – Effective January 1, 2021
Issued: December 16, 2020
Effective: January 1, 2021
The Canadian Car Repair Facility Labor Rate, effective January 1, 2021 is $206.64 CAD. This represents an increase of $24.38 CAD from the calculation for October 1, 2020. The changes to the rate involved updates to health & welfare rates, payroll taxes, January 1, 2021 wage increases, a new overhead study, and the currency conversion factor was updated for the January calculation.
The change will be reflected in the January 1, 2021 release of the Canadian Price Master.
C-13720
Informational Circular, Car Repair Facility Labor Rate – Effective January 1, 2021
Issued: December 16, 2020
Effective: January 1, 2021
The Car Repair Facility Labor Rate, effective January 1, 2021 is $130.66. This represents a decrease of 5.4% ($7.39) from the calculation for October 1, 2020. The changes to the rate involved health & welfare rates, payroll taxes, a new overhead study, and the addition of Shortlines and Running Repair Agents (RRA) to the calculation. This quarter’s Labor Rate utilizes Shortline and RRA wage rates, and the overall rate was calculated using the weighted average by classification (Class I, Shortline, and RRA) based on the new overhead study.
C-13722
Open Registration for 2021 AAR M-1003 Quality Assurance Basic Auditor and Root Cause Analysis Training Classes
Issued: December 16, 2020
Effective: Various Dates
The Association of American Railroads (AAR) Quality Assurance Committee (QAC) has scheduled all the 2021 Basic Auditor, Advanced Auditor and Root Cause Analysis Training classes. Registration is now open for the Webinar based training classes. A complete schedule is attached to the circular.
C-13723
Registration Is Open for the Virtual 2021 AAR Quality Assurance Auditor & Industry Conference
Issued: December 17, 2020
Effective: 30 days for comment
The Association of American Railroads (AAR) Quality Assurance Committee (QAC) is pleased to announce that the 33rd Annual AAR Quality Assurance Auditor & Industry Conference will be held May 11-12, 2021 as an Online Webinar and presentations will be open to all conference registrants. Additional information can be accessed at:
C-13727
January 2021 Field and Office Manuals, Summary of Comments and Implementation Details
Issued: December 31, 2020
Effective: December 31, 2020
In October and November 2020, 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 January 1, 2021. The circular includes a recap of those letters seeking industry comment, an indication of comments received (if any), consideration and implementation details.
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.