On May 1, 2018, the Association of American Railroads (“AAR”) issued Casualty Prevention Circular CPC-1332. The circular letter proposes to revise certain definitions and facility certification requirements contained within the AAR’s Manual of Standards and Recommended Practices, Section C, Part III, Specifications for Tank Cars. The proposed changes, if implemented, would increase the number of facilities that require facility certification, including facilities that manufacture or maintain tank car components. To help the regulated community understand the nature of the AAR circular and its alignment with the hazardous materials regulations issued by the Department of Transportation (“DOT”), James Rader, VP Regulatory Services, Greenbrier Management Services published an article for The Journal of HazMat Transportation. The Journal has agreed to have open access to the article. Interested readers can view the article.