Transport Canada's Protective Division 34
Announcement Number: AG2014-16
Categories: Ethanol and Biodiesel
Posted Date: May 23, 2014
Union Pacific is writing to provide guidance on the implications of Transport Canada's Protective Direction 34, which concerns certain DOT - 111 equipment used in transportation of Dangerous Goods within Canada. Those specific restrictions are noted below and become effective May 23, 2014.
TRANSPORT CANADA - PROTECTIVE DIRECTION - 34
1. Every tank car owner, as defined in CGSB 43.147-2005 (as amended July 2008), must immediately identify each of its tank cars that meet the following criteria:
A. The tank car is of stub sill design and of a CTC 111, DOT 111 or AAR 211 specification;
B. The tank car shell is made of non normalized ASTM A515 Grade 70 steel plates;
C. The bottom shell of the tank car does not have exterior heater coils; and
D. The bottom shell of the tank car is not continuously reinforced between the end of one of the stub sill’s reinforcing plate (stub sill cradle pad) to the end of the other stub sill’s reinforcing plate by reinforcing steel bars, steel plate or other structural shapes or by other structural elements such as a bottom discontinuity protection device.
2. A tank car owner must ensure that every tank car it identifies in 1) is marked with the words “Do not load with dangerous goods in Canada/Ne pas charger de merchandises dangereuses au Canada” or similar words to that effect.
3. No person shall offer for transport, transport, handle or import dangerous goods in a rail tank car that meets the description in 1) or has been marked in accordance with 2).
4. Despite 3), any dangerous goods in a tank car identified in 1) in transport on the day before this Protective Direction takes effect must arrive at their final destination within 30 days of the day this Protective Direction takes effect, where they must immediately be unloaded and the tank car must be marked in accordance with 2).
5. A tank car owner must provide the reporting mark of each car marked in 2) within 30 days of the day this Protective Direction takes effect.
As a result, rail cars that do not conform to PD 34 will no longer be accepted for use in Dangerous Goods service within Canada. This applies to cars shipped from or destined for Canada and applies to loaded and residue rail cars. Per the notice from the AAR on April 28, 2014, rail car owners are required to update the status of their rail cars with Railinc in UMLER. Effective May 23, 2014, if the field is not updated, by default, the field will reflect that the rail car does not meet the requirements. Accordingly, we have implemented a process to address affected cars that are billed to Canada. We will place these rail cars in a "PD hold" and they will not schedule for pickup from your facility.
Should a PD hold occur, you will be contacted by our National Customer Service Center to determine whether the rail car is actually non-compliant or improperly coded in the rail car status record of UMLER. If the rail car is non-compliant, you will need to provide new billing that is not destined to Canada or, if improperly coded in UMLER, you will need to contact the car owner to update the UMLER record. If in doubt about your cars' compliance status, you should contact the car owner or lessor to determine the appropriate status.
Union Pacific is committed to the safety of our employees, customers and the communities we serve. We appreciate your compliance with this order affecting shipments of Dangerous Goods to Canada.
If you have any questions please contact your Union Pacific representative.