For customers that we provide railcar maintenance services to, product spillage on railcars is sometimes a nagging railcar maintenance issue. It is most commonly caused when cars are mishandled off site by customers, terminal operators, or suppliers. Note that this article does not pertain to Non-Accidental Releases.
Zero product on the exterior is the standard for hazardous shippers. The rules are clearly stated in 49 CFR 173.24 “There will be no hazardous material residue adhering to the outside of the package during transport” and “All hazardous material which has leaked from a package in any rail car or on other railroad property must be carefully removed.”
Shippers of non-hazardous commodities should apply the same standard of care to assure there is no product on exterior. Not only does product dribbling down the sides of a railcar pose possible safety or environmental hazards, it also doesn’t look good from a public relations viewpoint. Railroads may allow small amounts on the exterior but large amounts that could foul up and adversely affect safety appliances (handrails, walkways, hand grabs) and perhaps cause unsafe working conditions are definitely cause for concern.
Prevention is the first step by providing detailed instructions to anyone involved with loading or unloading your railcars. The next step is to have a good inspection process in place so that you can immediately document and address issues as they happen. It’s important to constantly train and retrain loaders and off loaders, utilize inspection sheets, and track metrics to monitor performance.
Product spillage on tank cars happens most often with top offload through the product valve or top load though the manway cover or vent valve. Spillage happens by not clearing lines properly when disconnecting dribbling product on the fittings plate or sides, and not washing or wiping down properly when it does happen.
What do you do when you are notified there is product on the exterior of your tank cars at the loading or offloading points (assuming a non-emergency type of release)? The first step is to verify the car is holding a seal. Next we check that the product spillage was due to a loading or offloading spill and not a mechanical problem. If this cannot be done by the onsite personnel, we will call in a mobile repair unit to check seals and inspect the car to determine the cause of the leak.
Once the reason for the spill is known and it has been contained, if the spillage is significant the car may need to be cleaned prior to being moved. We check to see if the facility has a wash rack on site. If not, we may need to call in a mobile cleaning crew (subject to plant approval). It’s best to get before and after photos for verification that the product was actually cleaned off the exterior. If the car cannot be cleaned onsite, we may need to apply to the Federal Railroad Administration for a One Time Movement Approval to move the car to shop or back to the origin plant.