2002 TSB Recommendations & TC Responses

R99T0256 - Derailment - Canadian National Freight Train No. M304-41-21, Mile 202.98, Bala Subdivision - Near Britt, Ontario - 23 September 1999 (R02-01)(R02-02)

TSB Full Text Report (R99T0256):

TSB Recommendation R02-01

Classification of Anhydrous Ammonia - (Action Required, as presented in the TSB Report)

The Board recommends that:

The Department of Transport review the classification and safety marks for anhydrous ammonia to ensure that it is in a class and division consistent with the risks it poses to the public. (R02-01)

Transport Canada's Response (R02-01)

(signed by Minister on 23/09/2002)

The recommendation arises from a derailment involving three tank cars of anhydrous ammonia.

With respect to safety marks, there are three sources of information which must be visible on the tank car:

  • First, the words "ANHYDROUS AMMONIA" must appear in letters at least 100 mm high on each side of the tank.
  • Second, the words "Inhalation Hazard" or "Inhalation Hazard/Dangereux à inhaler" must appear in letters at least 100 mm high on each side of the tank.
  • Third, a placard must be visible on both sides and also on both ends to indicate the class assigned to anhydrous ammonia.

It is also observed that on the train consist (now required under the August 15, 2001 Transportation of Dangerous Goods Regulations) and on a shipping document the contents of the rail tank car would be shown to be anhydrous ammonia, either by the UN Name or the UN Number.

The Department is not aware of any instances in which the placard was the sole source of information for a rail tank car containing anhydrous ammonia.The name "ANHYDROUS AMMONIA" appearing on the side of the tank car is more useful in identifying the product.Further, given the response identified in the North American Emergency Response Guidebook (copies provided free of charge to each fire department and police department in Canada), Transport Canada's (TC) view is that the full information system, including the placard used, effectively provides information to responders.

However, TC will be writing to all fire departments in Canada with respect to certain items in the August 15, 2001 regulations to ensure all fire departments are aware of new provisions and at that time will reconfirm that anhydrous ammonia must be treated as toxic and that in special circumstances anhydrous ammonia can burn.

With respect to the classification of anhydrous ammonia, TC agrees that the UN classification of Class 2.3 (8) is an appropriate one. Indeed, under the August 15, 2001 regulations Transport Canada will accept the UN classification for shipments within Canada.

TC did attempt to have a special classification for anhydrous ammonia of Class 2.4 accepted at the United Nations, and within North America, but was unsuccessful. Subsequently, TC adopted in the August 15, 2001 regulations the classification as used in the United States.

TC will further consider the classification of anhydrous ammonia and will raise the matter at the next meeting of the Federal-Provincial Task Force and of the Minister's Advisory Council on the Transportation of Dangerous Goods.

Although anhydrous ammonia can burn, it does not meet the technical criteria for flammability. In order to be classified as a flammable gas, it must be ignitable when in a mixture of 13 per cent or less or have a flammability range of at least 12 percentage points. Anhydrous ammonia has a flammability range of 16-25 per cent, so it fails both criteria.

TSB Recommendation R02-02

Thermal Protection on 112J Tank Cars - (Action Required, as presented in the TSB Report)

The Board recommends that:

The Department of Transport, in conjunction with the tank car owners, review the existing inspection and maintenance program for thermal protection of tank cars already in service, and ensure that their thermal protection systems confer acceptable thermal resistance to reduce the risk of the premature release of dangerous goods in a fire. (R02-02)

Transport Canada's Response (R02-02)

(signed by Minister on 23/09/2002)

TC agrees with the recommendation and has been proactive in addressing this issue. Thermally protected tank cars in dangerous goods service must be re-qualified in accordance with sections 25.5.10 and 25.6.5 of the CAN/CGSB 43.147-2002 standard as part of the overall TC Safety Systems Inspection Program.

Since the beginning of the Safety Systems Inspection Program, with the CAN/CGSB 43.147-97 standard, TC has carried out audits on a number of different tank car shop facilities where these re-qualifications are being carried out. During these visits, a review of inspection procedures used for thermally protected tank cars was made; and in some cases exceptions were noted. Tank car shops were advised that they must revise their procedures. These inadequacies in shop procedures were further discussed with TC and re-inspections were ordered. Following these actions and in order to promote proper inspection techniques on an industry wide basis a task force was initiated under the auspices of the Association of American Railroads (AAR) tank car committee (Docket T65.7). Both TC and the Federal Railroad Administration (FRA) are part of this task force. Other research and development work pre-dating this task force has already been initiated by TC.

First established in June of 1996, the TC sponsored "Field Detection of Tank Car Insulation Deficiencies” project has undertaken laboratory experimentation, field trials, and image analysis in a successful attempt to establish the feasibility of using thermography to detect discontinuities in thermal protection under tank car steel jackets in the presence of a thermal gradient. This project was a success.

These studies and inspection techniques already developed are being shared with the members of the AAR tank car committee.

TC is continuing it's research studies to determine the effect of thermal protection defects on the re-qualification of tank cars and is currently developing a tool for scientifically determining the maximum acceptable deterioration of thermal protection.This tool will be used to develop an acceptance criteria for use by TC inspectors and once developed will also be shared with members of the AAR tank car committee.

TC inspectors will continue to assess the adequacies of the inspection techniques/procedures used by tank car owners as part of the TC oversight activities of tank car facilities.

R99H0010 - Derailment and Collision - Canadian National Train No. U-783-21-30 and Train No. M-306-31-30 - Mile 50.84, Saint-Hyacinthe Subdivision -Mont-Saint-Hilaire, Quebec, 30 December 1999 (R02-03)(R02-04)(R02-05)

TSB Full Text Report (R99H0010):

TSB Recommendation R02-03

Regulations on Emergency Response Plans for the Transportation of Hydrocarbons - (Action Required, as presented in the TSB Report)

Tthe Board recommends that:

Transport Canada review the provisions of Schedule I and the requirements for emergency response plans to ensure that the transportation of liquid hydrocarbons is consistent with the risks posed to the public. (R02-03)

Transport Canada's Response (R02-03)

(signed by Minister on 19/12/2002)

Transport Canada (TC) supports this recommendation and has already begun a review as recommended by the Board. TC’s Emergency Response Assistance Plan (ERAP) program is in place so that shippers of certain dangerous goods can provide specialized knowledge to local emergency response authorities at the scene of an accident. Examples of dangerous goods requiring specialized knowledge as well as unique tools or techniques include chlorine, plutonium, propane or anhydrous ammonia). However, TC will review the possibility of extending this requirement to shippers of large quantities of other dangerous goods, such as hydrocarbons.

In light of the TSB recommendation, a discussion paper was developed and presented in November 2002 at both the Federal-Provincial/Territorial Transportation Dangerous Goods (TDG) Task Force and the TDG General Policy Advisory Council meetings. The discussion paper provided an overview that describes the central purpose of ERAP’s and current criteria used to mandate ERAP use; outlined the possible new criterion of large quantities of flammable commodities requiring an ERAP; and reviewed the accident circumstances at Mont Saint-Hilaire. Members of both the TDG Task Force and General Policy Advisory Council have been requested to provide their comments on the discussion paper prior to the end of 2002. Decisions on further actions are expected following a review of the comments and a formal assessment by TC.

TSB Recommendation R02-04

Design Specifications for Event Recorders - (Action Required, as presented in the TSB Report)

The Board recommends that:

Transport Canada ensure that the design specifications for locomotive event recorders include provisions regarding the survivability of data. (R02-04)

Transport Canada's Response (R02-04)

(signed by Minister on 19/12/2002)

TC supports this recommendation and recognizes the need to extend the existing design and construction standards for locomotive event recorders to address data survivability or “crashworthiness” which is not addressed at this time. The Federal Railroad Administration (FRA) in the U.S. is presently developing a rule on the crashworthiness of locomotive event recorders that would be similar to the standards for aeronautical and marine event recorders.

TC is a member of the Railroad Safety Advisory Committee (RSAC), which is chaired by the FRA and comprises the North American railways, unions and other stakeholders. The RSAC is a collaborative effort that provides advice and recommendations from industry on a range of regulatory issues. In 1997, RSAC initiated a Working Group (WG) to address the issue of what data elements should be recorded, inspected, tested and maintained, physical location, as well as survivability of the event recorder.

TC is closely following the development of the proposed U.S. rule. It is anticipated that the U.S. rule will be finalized in August 2003, at which time TC will review the U.S. rule and initiate a similar rule-making process in Canada.

TSB Recommendation R02-05

Requirements for the Quality Control of Thermite Welds - (Action Required, as presented in the TSB Report)

The Board recommends that:

Transport Canada review the requirements for the inspection and quality control of thermite field welds to ensure that an adequate level of safety is maintained on all types of tracks. (R02-05)

Transport Canada's Response (R02-05)

(signed by Minister on 19/12/2002)

TC supports this recommendation and has already initiated a review on all types of rail welds currently performed by railways, as well as the type of inspection and testing conducted of these welds. TC is undertaking this review with the objective of identifying any areas where safety practices can be enhanced.

As part of this review, TC has been in regular discussions with both Canadian National (CN) and Canadian Pacific (CP) to help the railways assess the current level of adequacy of the quality of field welds. The assessment will help to determine how soon after a thermite weld is poured, it is tested for flaws or defects for each class of track and when all thermite welds have been inspected, to determine whether there are any that are sitting on or tight against tie plates.

TC expects that the review of field welds will be completed by December 31, 2002. Once completed, the review will provide the necessary information to determine the adequacy of inspections, maintenance and quality control of thermite welds for all types of tracks. Depending on the results of the review, CN may be required to modify its policy. Furthermore, to assure consistency among railways in Canada, the results of the review will be analyzed by TC’s WG on Track Safety Rules. This WG has been recently created to recommend amendments to Track Safety Rules and railway industry practices. The WG is comprised of representatives from the railways, the unions, and TC. It is anticipated that, on the issue of field welds, the WG will consider improvements to existing railway policies or that new policies be issued, where required.

In the interim, TC continues to work with CN and CP to ascertain that both companies are maintaining and executing all rail welds in compliance with existing standards and procedures.

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