AAR Circular Letter Summary – September 2021



About AAR Circular Letters

Circular letter summaries are produced monthly by Greenbrier’s Regulatory Management team, a division of Greenbrier Management Services Group.

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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

IMPLEMENTED.  AAR Manual of Standards and Recommended Practices (MSRP), Section K-II Locomotive Electronics and Train Consist System Architecture, Specification M-9155.V2.4.1.
Issued: September 10, 2021
Effective: September 10, 2021

Specification M-9155.V2.4.1 describes functional requirements in sufficient detail and accuracy to support technical proposals to develop a Locomotive Command and Control Module (LCCM) standalone device or to develop the LCCM function as part of the OEM locomotive control system. The specification is attached to the circular in PDF format. M-9155.V2.4.1 will be incorporated into the next issue of the MSRP, Section K-II Locomotive Electronics and Train Consist System Architecture.  In the interim, please insert the Circular in your copy of the MSRP Section K-II and be governed accordingly.


Call for Comment

Solicitation for Comments for Revisions to MSRP Section J, Specification for Quality Assurance M-1003
Issued: August 31, 2021
Effective: 30 days for comment.

This Circular Letter supersedes Circular Letter C-13838 in its entirety including attachments. A PDF of the proposal is attached to the circular.

Changes include:

  • Guidance added for termination or rescheduling of audits.
  • Language updated to reflect current computer technology.
  • “Transgressions” were removed as a finding type.
  • Important clarifications and guidance edits made by the QAC.


Notice of Circulars

Fall 2021 AAR Technical Committee Meetings
Issued: September 1, 2021
Effective: September 1, 2021

With respect to the COVID-19 pandemic, the AAR has determined that for the second half of 2021, AAR In-person committee meetings are open only to those fully vaccinated for COVID, at least two weeks past final vaccination.  Virtual meetings may be held in lieu of in-person meetings if that is preferred.  In-person meetings may be considered private for committee members only or they may be open to the public, and that decision is up to each committee.  Additionally, AAR-hosted meetings will abide by CDC, State, and local guidelines, which call for masks to be worn in public indoor settings in areas of substantial or high transmission (nearly all the United States at this time). A full schedule of dates, locations, and the type of meeting are included the circular.


Informational Circular, Canadian Car Repair Facility Labor Rate – Effective October 1, 2021
Issued: September 10, 2021
Effective: September 10, 2021

The Canadian Car Repair Facility Labor Rate, effective October 1, 2021 is $206.06 CAD. The change will be reflected in the October 1, 2021 release of the Canadian Price Master.


Informational Circular, Car Repair Facility Labor Rate – Effective October 1, 2021
Issued: September 10, 2021
Effective: September 10, 2021

The Car Repair Facility Labor Rate, effective October 1, 2021 is $131.73. The change will be reflected in the October 1, 2021 release of the AAR Office Manual.


Upcoming Events

PNWARS 2021 Fall Meeting–Virtual Conference
October 13-14, 2021

GBX is a proud sponsor at the PNWARS Fall Virtual Conference.


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.



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.