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
Implementation of Revision to AAR MSRP Section J, Specification for Quality Assurance M-1003
Issued: January 10, 2022
Effective: July 1, 2022
The AAR Quality Assurance Committee (QAC) has announced a new edition of the Manual of Standards and Recommended Practices (MSRP) Section J, Specification for Quality Assurance M-1003. Since the last printing issued in October 2019, the QAC issued one revision through Circular Letter C-13644 (dated September 4, 2020) to update the Activity Code listing in Appendix A. The effective date of this release is July 1, 2022, allotting six months for M-1003 programs to be revised accordingly. Auditors will not identify nonconformance findings related to the new revision until July 2022. However, AAR accredited auditors will immediately identify items of concern related to the revision to bring attention to the pending requirements. The manual can be purchased online at www.aarpublications.com.
The QAC has selected the following mandatory elements to be audited in 2022:
- 6 – Corrective and Preventive Actions
- 15 – Process Control
- 18 – Nonconformance Control
- 21 – Internal Quality Audits
C-13925
Implementation Circular: MSRP Section F, Sensors, Standard S-6101, Detector Calibration & Validation Requirements: Acoustic Bearing Detector (ABD) Validation Standards
Issued: January 11, 2022
Effective: January 11, 2022
The Equipment Health Monitoring Committee (EHMC), jointly with the Wheels, Axles, Bearings & Lubrication (WABL) Committee is releasing this implementation circular to notify the industry of the implemented addition to the subject standard within AAR’s Manual of Standards & Recommended Practices (MSRP), Section F – Sensors. The additions, attached to the circular, 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
Call for Comment
C-13923
DRAFT S-9452.V3.0 – ITCSM Common Data Dictionary for Interoperable Train Control is available for review and comment. In support of AAR’s MSRP – Section K-V, Electronics Environmental Requirements and Systems Management
Issued: January 7, 2022
Effective: 10 days for comment.
ITC Systems Management (ITCSM) produces specifications for how the system management infrastructure should be built, for what all ITC Asset types should support, and for what each individual ITC Asset type should support. there are several documents that detail out these specifications. This ITCSM Common data Dictionary is one of those documents. The purpose of the data dictionary is to provide an efficient mechanism to capture and relay asset information to the railroad back office. Each ITC Asset vendor shall create a data dictionary for each individual asset model. The data dictionary is shared between the asset and the back office. SharePoint access can be found at www.railinc.com.
DRAFT S-9413.V1.0 – SMIA-2 Interoperable SMIA-2 Gateway Requirements Recommended Practice is available for review and comment. In support of AAR’s MSRP – Section K-V, Electronics Environmental Requirements and Systems Management.
Subject
Issued: January 7, 2022
Effective: 10 days for comment.
The SMIA-2 Gateway is the interoperable systems management gateway used for exchanging system management messages between back offices. The SMIA-2 gateway is not used for exchanging system management messages with remote assets. This document describes the gateway behavior upon receipt of an interoperable systems management message. The scope of this document includes receipt of interoperable systems management messages from a domestic source and from a foreign SMIA-2 gateway. This document is applicable to all SMIA-2 messages, and other services that leverage the SMIA-2 infrastructure. SharePoint access can be found at www.railinc.com.
C-13926
DRAFT S-9418.V1.0 – PSA-2 Gateway Requirements is available for review and comment, in support of AAR’s MSRP – Section K-V, Electronics Environmental Requirements and Systems Management.
Issued: January 11, 2022
Effective: 10 days for comment.
This document the security aspects of PSA-2 as they relate to the Systems Management Gateway. The scope of this document includes requirements for ITCSM gateway to support PSA-2. SharePoint access can be found at www.railinc.com.
C-13930
Solicitation of Comments for Revisions to AAR Intermodal Interchange Rules, Appendix F Job Codes for GPS Components on Chassis and Containers
Issued: January 28, 2022
Effective: 30 days for comment.
The draft (attached to the circular) to Appendix F includes the addition of Job Codes for repair and replacement of GPS components on chassis and containers. The proposed revisions to Section F do not have costs associated with implementation.
CPC-1381
Solicitation of Comments on Proposed Revisions to MSRP Section C-III, Specification for Tank Cars (M-1002), Chapter 1, Chapter 2, and Appendix B
Issued: January 31, 2022
Effective: 30 days for comment.
The Tank Car Committee (TCC) is soliciting comments on the proposed revisions to Chapter 1, Chapter 2, and Appendix B of AAR MSRP C-III, Specifications for Tank Cars (M-1002). The drafts are attached to the circular.
Summary of Revisions:
Chapter 1
Updated Table 1.1 with DOT117 specification including notes.
Updated paragraph 1.2.1.1 for DOT-117 class tank car.
Updated paragraph 1.2 definitions to align with revisions to Chapter 2 and Appendix B.
Updated paragraph 1.4 for the process of approving underframes of an untried type.
Chapter 2
Updates to reflect new construction and retrofit requirements for Non-Pressure Tank Cars used to transport class 3 flammable liquids.
Updates to reflect phase out of DOT/TC-111 tank car design used transport class 3 flammable liquids.
Update to reflect reclosing pressure relief valve having a start-to-discharge of 75 psi for DOT-117 class tank car transporting ethanol or crude oil.
Clarifying the use of the term CPC-1232 and enhanced DOT/TC111.
Appendix B
Update tables and paragraphs for reserved activity codes B87 and C12 along with demonstration capability.
developed repair level capability for Locomotive fuel tender.
Updated service equipment category H for heater systems from “reserved.”
Updates to tables and paragraphs for service equipment category H – Heater systems.
Updates to administrative provisions based on online system integration.
Updates to administrative provisions for termination of audits.
Updates to Exhibit B-1 and Exhibit B-3a based on proposed revisions to Appendix B and online system integration.
Notice of Circulars
C-13928
2022 AAR M-1003 Quality Assurance Auditor Training Class Schedule
Issued: January 19, 2022
Effective: Refer to circular for full schedule
The Association of American Railroads (AAR) Quality Assurance Committee (QAC) has finalized the schedule for the 2022 AAR M-1003 Quality Assurance Training classes. Classes include Basic Auditor training, Advanced Auditor training and Root Cause Analysis class. All attendees must be fully vaccinated against COVID-19.
C-13927
Registration Is Now Open for the April 2022 AAR Quality Assurance Auditor & Industry Conference
Issued: January 19, 2022
Effective: January 19, 2022
The Association of American Railroads (AAR) Quality Assurance Committee (QAC) has announced the 34th Annual AAR Quality Assurance Auditor & Industry Conference to be held April 12-14, 2022, in Fort Worth, Texas. All attendees must be fully vaccinated against COVID-19. Registration and hotel information can be found online at 2022 AAR Quality Conference.
C-13929
Correction to the January 1, 2022 Release of the Office Manual – Rule 112.E.1.c
Issued: January 26, 2022
Effective: January 26, 2022
After the issuance of the January 1, 2022, Office Manual, it was identified that editorial changes to Rule 112.E.1.c are required. The entirety of the changes are detailed below.
Office Manual Rule 112.E.1.c (page 102):
Detail Source JD JI must be billed within 6 months from the date of repair. Detail Source
repairs made in January, the bill must be received by the billed party, as defined in
Rule 112.H.2, no later than the August Data Exchange (the date in August that the
Detail Source data supporting the invoice is available).
This circular letter is identified as mandatory in accordance with Field Manual Rule 1.5.b.(11) and must be maintained until the next revision of the Office Manual is published. There will be no reissue the Office Manual until the regularly scheduled April 1, 2022, revision. Instead, subscribers are directed to print the attached changed pages and insert into the Office Manual, replacing pages 101-102.
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.