Chemical Transportation Safety Update
The Hazardous Materials Transportation Act and DOT HazMat regulations (49 USC S 5110(a) and 49 CFR Part 172 Subpart C) require that a customer provide complete and accurate shipment documentation when offering hazardous materials to a carrier for transportation. DOT rules also prohibit a railroad from accepting a hazardous materials shipment without this information, and requires the information to accompany the shipment , 49 CFR Part 174, Subpart B. To comply with these requirements, it is necessary that this shipping information be in our data systems before a loaded or empty hazardous rail car is released for movement.
As a Responsible Care Partner company, we are committed to ensuring the safest possible environment and handling of hazardous materials. As part of that commitment, we review and analyze billing processes that do not meet our business requirements.
Through our analysis we have found that occasionally a company's hazardous material shipment is not billed before it is released to us, which is a violation of the above requirements. This is unacceptable to Union Pacific from a safety, security, and regulatory standpoint. If an incident with the product occurred during transport without billing or while awaiting billing, we would have no information for emergency responders, nor could we protect the shipment during a security alert. Also, both Union Pacific and the customer could receive an FRA citation with a $25,000 daily fine for lack of billing information.
The following standards are currently in effect:
- Billing must be in UP's system before the car is released for the car to be accepted by Union Pacific employees.
- When Union Pacific employees arrive to pull the cars, the first hazardous car without billing and all subsequent cars in that cut will be left behind at the customer's facility or interchange point.
Union Pacific stands ready to assist you in correcting issues that may lead to a "no bill." We strongly encourage you to submit all of your billing transactions electronically (EDI). We continually evaluate and improve our EDI processes and will work with you to eliminate any UP-caused billing errors.
EDI information can be found here, or call our EDI help desk at 800-872-1045. To discuss recent no bills and their possible causes, please contact your Union Pacific Representative.
Responsible Care Management System (RCMS)
Responsible Care is a safety, health, environmental and security program developed by the chemical industry as a continuous improvement process for members and also to show their efforts the public. Non-chemical companies that handle their products, such as railroads, were allowed to join in 1995, with UP becoming the first railroad to sign on. Responsible Care asks that you establish a "management system" for your safety, health, environmental and security processes, and all members/partners are required to be audited and certified to the management standard.
Demonstrating commitment to chemical customers and the safe handling of hazardous materials, Union Pacific met certification requirements under the RCMS program in the Fall of 2010. Valid until Dec. 31, 2013, the certification resulted from a six-month team effort. Representatives from Safety, Environmental Management, Operating, Security, Human Resources, Marketing and Sales, and Information Technologies completed an in-depth, independent safety and process audit through Midland Engineering.
The final audit report contained feedback regarding UP's processes and conformance, including:
- The "Plan, Do, Check and Adjust" continuous improvement cycle;
- The employee-owned Total Safety Culture initiative;
- A strong and multi-faceted security program, including a UP hazmat and emergency response program noted as the "best seen" by the audit team;
- Strong, established relationships with local agencies along UP right of ways;
- The UP Environmental Stewardship Program, and
- An online document management site, RCMS Quickr, promoting efficient communication between UP and external auditors.
For more information regarding RCMS and chemical transportation safety, please call Craig Johnson, General Director-Chemical Transportation Safety, at 402-544-3520 or send an email.
DOT Hazardous Materials Compliance
Re: 49 CFR Part 172
This advisory is to certify that Union Pacific Railroad has developed and implemented a security plan in compliance with the Department of Transportation Final Rule 49 CFR Part 172 Hazardous Materials (HM 232): Security Requirements for Offerors and Transporters of Hazardous Materials.
Should you have any comments or questions, please call Chad Deasy, Director Homeland Security, (402) 544-8825, or send an email.
Hazardous Materials Initiatives
Time Sensitive Car Tracking
A UP team in the National Customer Service Center (NCSC) tracks hazardous material commodities which are deemed "time sensitive" shipments, due to their chemical nature. These products must reach their destination within a given time period or they may start a chemical reaction and possibly cause a release.
To safeguard against a release occurring, UP was the first railroad to monitor every time sensitive shipment on a daily basis. If a car appears to be delayed enroute, a series of calls are initiated by management to ensure arrival of the product within the designated time period. Since beginning this process, there have been no car releases of time sensitive products. We also provide a list of time sensitive cars going to each carrier for their advanced planning.
Non-Accident Release Program
A non-accident release is described as any release of hazardous materials from leaks, splashes and venting from safety devices. UP works to prevent all hazmat releases, even those not caused by derailments. Inspections of tank cars, as well as non-accident release (NAR) inspections and measures, are implemented. If a tank car is determined to need repairs, the shipper is notified.
The Top Ten Practices For Rail Shippers
- Develop and implement a securement policy which includes pre-loading inspections, post loading inspections and corresponding safety checklist.
- Special attention should be given to ensure that no overloading of rail cars occurs especially hazardous materials.
- Perform extra inspection of valves/domes for tightness (one of the leading causes of leaks/spills in rail transportation incidents).
- After loading, leak-test the car by applying at least 10 psig of pressure over the maximum estimated transportation pressure. All valves, packing gland nuts, closures and flanges should be checked using leak detection solution or ultrasonic instrument. After completing the leak test, pressure should be released or reduced.
- If a pressure test is impractical or unsafe, the car should be held and reinspected after twenty-four (24) hours, and valves and fittings re-tightened as needed to ensure proper securement.
- Review shipping papers to ensure adequate data.
- Promote Electronic Data Interchange (EDI) for all shipments.
- Ensure that proper placarding is maintained for all rail cars.
- Utilize recto-reflective placards, requirements for bulk consignments per Item 5.27 of the Canadian TDG regulations.
- Shippers should eliminate using paper placards whenever possible.
- Ensure that the Emergency Response Plan is correct and updated for plant sites and transportation related releases.
- Ensure that the Emergency Response Plan is exercised annually (drill).
- Shippers must show proper ERP number and associated telephone number on dangerous goods subject to the EDP requirements of Transport Canada.
- Ensure that emergency contacts and telephone numbers for the railroad and plant site are correct and updated regularly.
- Key training programs that should be implemented are:
- All railroad personnel who enter the plant site are properly trained and/or receive orientation (especially for emergency actions).
- Establish, document, communicate and implement a company-wide tank car securement training program.
- Establish, document, train and implement a procedure for tank car customers to report poor securement, hard to operate valves and other fitting problems.
- Establish, document, train and implement companywide preventive maintenance practices for tank cars.
- Ensure that all rail crossings within the plant site are properly marked with warning signs.
- Ensure rail lines are clear, switches are aligned properly, and car brakes are released before moving cars.
- Have plant personnel closely observe rail crews when they are operating within the plant site to assure plant and rail safety are being maintained.
- Have a documented routine process for providing feedback to the rail carrier.