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-13585
Implementation of Revisions to MSRP Section B, FREIGHT CAR DRAFT COMPONENTS, Specification M-921B Cushioning Devices, End-of-Car. Addition of New Requirements.
Issued: May 13, 2020
Effective: May 2020
New requirements have been added to the Specification to fully document the performance and physical condition of devices after service testing. These modifications will be incorporated into the next issue of the Manual of Standards and Recommended Practices, Section B. Please update your library and be governed accordingly.
C-13583
Implementation of Editorial Revisions to Figure 88-B – Section 6 of the AAR Open Top Loading Rules Manual (OTLR)
Issued: May 13, 2020
Effective: May 13, 2020
Revisions to Section 6, Figure 88-B have been made to clarify language and add a reference to the Transportation Engineering Agency for “Tiedown Instructions for Rail Movements.” The implementation of these revisions is effective immediately and will be included in the next edition of the OTLR manual. In the interim, please insert the circular attachment for Figure 88-B in your Section 6 copy and be governed accordingly.
C-13584
Implementation of Revisions to General Rules 5, 19, 21 and Glossary – Section 1 of the AAR Open Top Loading Rules Manual (OTLR)
Issued: May 13, 2020
Effective: May 13, 2020
The implementation of the revisions is effective immediately and will be included in the next edition of the OTLR manual. In the interim, please insert the circular attachments for General Rules 5, 19, 21 and the Glossary into your Section 1 copy and be governed accordingly.
C-13587
Implementation of Revisions to Figures 54 and 54-B from Section 5, and General Rule 12 from Section 1 of the AAR Open Top Loading Rules Manual (OTLR)
Issued: May 19, 2020
Effective: May 19, 2020
The implementation of the revisions is effective immediately and will be included in the next edition of the OTLR manual. In the interim, please insert the circular attachments for Figures 54 and 54-B from Section 5, and General Rule 12 from Section 1 and be governed accordingly. Carriers are asked to ensure that copies of this circular letter are distributed to all concerned shippers and railroad personnel for their attention and guidance.
C-13588
Implementation of Revisions to Figures 13, 113 and 116 from Section 5 of the AAR Open Top Loading Rules Manual (OTLR)
Issued: May 21, 2020
Effective: May 21, 2020
The implementation of the revisions is effective immediately and will be included in the next edition of the OTLR manual. In the interim, please insert the circular attachments for Figures 13, 113 and 116 from Section 5 and be governed accordingly. Carriers are asked to ensure that copies of this circular letter are distributed to all concerned shippers and railroad personnel for their attention and guidance.
CPC-1367
Impacts related to AAR M-1003 QAP requirements for M-1002/M-1003 Certified Tank Car Facility Certification due to COVID-19
Issued: May 27, 2020
Effective: March 17, 2020 and expires December 31, 2020
The focus of this circular is on the potential impact COVID-19 restrictions have on facilities to receive services by the subcontractor or employees not located at the facility being audited for the following services:
- DOT HazMat General & Function Specific Recurrent Training
- AAR M-1002 Appendix T NDT Recurrent Training
- AAR Exhibit B-1’s Subcontractors who provide services in accordance with Appendix B paragraph 3.4.1 which for clarity are:
- Interior coating inspector per Appendix L
- Interior lining inspector per Appendix L
- Welding inspector per Appendix W
- NDT personnel (level I, II, and III) per Appendix T
- LPWHT per Appendix R
- Hardness testing per Appendix W
- Engineering services
- Metallurgical or physical lab services
- M-1002 Visual Acuity Eye exams
The conditions set forth in this circular are in effect for AAR M-1002/M-1003 audits performed between March 17, 2020 and December 31, 2020. The list of items below must show compliance prior to March 17, 2020 and the corresponding expiration occurs prior to December 31, 2020. The outlined conditions in this CPC is subject to change at any time.
C-13592
Implementation of Revisions to Figures 150, 420, 421, 422, 460, 461, and 462 from Section 3 of the AAR Open Top Loading Rules Manual (OTLR)
Issued: May 28, 2020
Effective: May 28, 2020
The implementation of the revisions is effective immediately and will be included in the next edition of the OTLR manual. In the interim, please insert the circular attachments for Figures 150, 420, 421, 422, 460, 461, and 462 from Section 3 and be governed accordingly. Carriers are asked to ensure that copies of this circular letter are distributed to all concerned shippers and railroad personnel for their attention and guidance.
Call for Comment
C-13577
Solicitation of Comments, Revisions to Field Manual, Rule 9
Issued: May 8, 2020
Effective: 30 days for comment Targeted implementation date is July 1, 2020)
The entire text of the proposal for changes to Rule 9 (Air Brake Cylinders and Parts), is attached to the circular.
C-13586
Solicitation of Comments, Revisions to Field and Office Manuals, Rule 59, Component Tracking
Issued: May 15, 2020
Effective: 30 days for comment
A proposal to revise Rule 59 (Cushioned Underframe Devices) to support the addition of cushion units to the AAR Component Registry. The entire text of the revision and proposed implementation dates are included in the circular.
C-13589
Solicitation of Comments: Revisions to MSRP Sec.F, SENSORS, Std S-920 AAR Component Identification Bar Code Std, and MSRP Sec.B, FREIGHT CAR DRAFT COMPONENTS, Cushioning Devices Spec.M-921B-C-D-E-F. Addition of Component Tracking for Cushioning Devices
Issued: May 21, 2020
Effective: 30 days for comment
Revisions to Standard S-920 address the addition of Cushioning devices to the Component Tracking process. Cushioning device manufacturers and reconditioners will be required to add approved AAR bar code labels to their product by January 1, 2021. Early compliance is encouraged as component registration, association, and field registration will be available by October 1, 2020. Additional information regarding related changes to the Field Manual of the AAR Interchange Rules and the Car Repair Billing System can be found in Circular C-13586, released on May 15, 2020.
C-13590
Solicitation of Comments, Revisions to Field and Office Manuals Rule 125, Early Warning
Issued: May 22, 2020
Effective: 60 days for comment
The revision of Rule 125 (Early Warning /Maintenance Advisory) is intended to support the rewrite of the Early Warning System (scheduled for implementation on January 1, 2021) and provides enhanced functionality and a more streamlined process. The entire text of the revision is attached to the circular.
Notice of Circulars
C-13574
Informational Circular, Revisions to Field Manual, Rule 59
Issued: May 4, 2020
Effective: May 4, 2020
Field Manual Rule 59 (Cushioned Underframe Devices) has been revised. Section A.1.m has moved to A.1.h and a new cracked cross key image has been inserted. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13573
Informational Circular, Revisions to Field Manual, Rule 23
Issued: May 4, 2020
Effective: May 4, 2020
Field Manual Rule 23 (Articulated Connectors) has been revised. Crack criteria has been updated to better reflect observed conditions. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13571
Informational Circular, Revisions to Field Manual, Rules 47, 48 and 90
Issued: May 4, 2020
Effective: May 4, 2020
Field Manual Rules 47 (Truck Bolsters), 48 (Truck Side Frames, Transoms and Spring Planks) and 90 (Cars and/or Car Parts Prohibited in Interchange) have been revised for increased component life. The entire text of the revisions is included in the circular. The revisions will be included in the July 2020 update to the Field Manual.
C-13570
Informational Circular, Revisions to Field Manual, Rules 47 and 48
Issued: May 4, 2020
Effective: May 4, 2020
Field Manual Rules 47 (Truck Bolsters) and 48 (Truck Side Frames, Transoms and Spring Planks) have been updated. The entire text of the revisions is included in the circular. The revisions will be included in the July 2020 update to the Field Manual.
C-13569
Informational Circular, Revisions to Field Manual, Rule 41.A.E, Maanshan Wheels
Issued: May 4, 2020
Effective: May 4, 2020
Rule 41 (Wheels) Section E.7.f has been revised to correctly align with Rule 41.A.1.x. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13568
Informational Circular, Revisions to Field Manual, Rule 41.A.1, Wheels
Issued: May 4, 2020
Effective: May 4, 2020
Rule 41 (Wheels) Section A.1.o has been updated with two new figures. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13567
Informational Circular, Revisions to Field Manual, Rule 22
Issued: May 4, 2020
Effective: May 4, 2020
Rule 22 (Uncoupling Levers and Support Brackets) has been updated to address the A1 criteria for “Cracked” in Rule 22, with a Why Made Code in the related job codes. The entire text of the revision is included in the circular. The revisions will be included in the July 2020 release of the Field Manual.
C-13566
Informational Circular, Revisions to Field Manual, Rule 21, Draft Gears
Issued: May 4, 2020
Effective: May 4, 2020
Rule 21 (Draft Gears, Carriers and Followers) has been updated. The entire text of the revisions is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13565
Informational Circular, Revisions to Field Manual, Rule 18.E and Appendix A, Anti-creep
Issued: May 4, 2020
Effective: May 4, 2020
Rule 18 (Couplers Type F and Parts), Section E.5 and Appendix A have been revised to provide clarity and Figure 18.12 has been updated. The entire text of the revisions is included in the circular. The revisions will be included in the July 2020 update to the Field Manual.
C-13576
Informational Circular, Revisions to Field and Office Manuals, Rule 107.B.2
Issued: May 7, 2020
Effective: May 7, 2020
Rule 107.B.2 (Handling of Damaged or Destroyed Equipment) has been revised. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13575
Informational Circular, Revisions to Field and Office Manual, Rule 91.5
Issued: May 7, 2020
Effective: May 7, 2020
Rule 91.5 (Service Interruption) has been revised for clarification on the intent of the rule. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13582
Updated Schedule for 2020 AAR M-1003 Basic Auditor, Advanced Auditor and Root Cause Analysis Training Classes
Issued: May 8, 2020
Effective: Schedule included in circular
The AAR Quality Assurance Committee (QAC) has rescheduled some 2020 Basic Auditor, Advanced Auditor and Root Cause Analysis Training classes, and has moved other classes to a Webinar-based training format. Class descriptions and a revised schedule is included in the circular.
C-13581
Informational Circular, Revisions to Field Manual, Rule 61, Body Side Bearings
Issued: May 8, 2020
Effective: May 8, 2020
Rule 61 (Body Side Bearings) has been updated. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13578
Informational Circular, Revisions to Field Manual, Rule 89, Conditions Governing Delivery and Acceptance
Issued: May 8, 2020
Effective: May 8, 2020
Rule 89 (Conditions Governing Delivery and Acceptance) has been updated. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13579
Informational Circular, Revisions to Field and Office Manuals, Appendix B
Issued: May 8, 2020
Effective: May 8, 2020
Field & Office Manuals Appendix B (Chock Replacement Guidelines) has been revised. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13580
Informational Circular, Revisions to Field Manual, Rule 64
Issued: May 8, 2020
Effective: May 8, 2020
Rule 64 (Tie Down and Load Restraining Devices) has been revised. The entire text of the revision is included in the circular. The revision will be included in the July 2020 update to the Field Manual.
C-13591
Temporary Extension of Specific AAR M-1003 Quality Assurance Requirements Due to COVID-19
Issued: May 26, 2020
Effective: March 17, 2020 and expires December 31, 2020
At the request of the industry, the AAR Quality Assurance Committee (QAC) is granting a temporary extension of the following M-1003 Quality Assurance requirements due to COVID-19 restrictions on travel, and health concerns:
- Training
- Internal Audits
- Calibration
- Audit Findings
This temporary extension is not a waiver of the M-1003 requirements, but an extension to the specific timeframes outlined in Chapter 2 of the M-1003 Quality Assurance Specification. The AAR QAC is granting this temporary extension of specific timeframes be contingent on each M-1003 certified facility having a documented recovery plan in place at the time of the scheduled AAR M-1003 audit. AAR Accredited Auditors will be instructed to take exceptions in the areas listed above as normal audit non-compliances, if they apply, and to accept the M-1003 certified facility responses with references to the documented recovery plan.
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.