From a haulers’ perspective or from a private contractor or municipality that contracts with a rail transporter, its important to understand that there are specific railcar repair rules that apply to a waste-by-rail transport operation.
Darell Luther
With a total of seven Class I Railroads and more than 500 Regional, Shortline, Switching and Terminal Railroads that operate over 169,000 miles of railroad tracks transporting or providing storage for over 1.6 million railcars, it sounds like a menagerie of confusion just waiting to occur! So what governs railcar repairs, how do those railcars get repaired and how are those repairs accounted for in this system?
As a waste hauler considering waste-by-rail alternatives or as a municipality contracting with a waste hauler that transports Municipal Solid Waste, Construction and Demolition Debris, Contaminated Soils or other waste streams by rail it’s important to know that there is a system in place to account for maintenance of railcars.
Rules and Regulations
Believe it or not there is some structure to the chaos! The Federal Railway Administration (FRA) and the Association of American Railroads (AAR) publish a set of rules and regulations that all railroad railcar owners, whether owned privately or owned by a railroad, must subscribe to in order to run their railcars on a railroad. The FRA rules and regulations are contained in Title 49 of the Code of Federal Regulations. These rules and regulations set minimum mechanical requirements with the emphasis on safety. Violations of federal rules are dealt with by harsh fines ranging from $5,000 per occurrence to $15,000 per occurrence.
The AAR rules are more detailed and are formulated in two manuals, designated “AAR Field Manual” and “AAR Office Manual”. These manuals, somewhat detailed and voluminous in size with the Field Manual being in excess of 700 pages and the Office Manual being in excess of 500 pages, are guides to the fair and proper handling of freight traffic for interchange. The Field Manual generally describes when and under what circumstances a repair should be made and the Office Manual describes what charges can be made for the repair. There are two specific overriding rules in both these manuals that set the guidelines for railcar owners, a paraphrase of these Rules is stated below.
Rule A with the intent of:
- Making railcar owners responsible for and therefore chargeable with the repairs to their cars necessitated by ordinary wear and tear and in fair service, safety requirements and by the Standards of the Association of American Railroads.
- Placing responsibility with and providing a means of settlement for damage to any car, occurring through unfair usage or improper protection by the handling company.
- Providing a means of determining usage charges for component repairs.
- Providing for an equitable basis for charging repairs and damages.
- Allowing for acceptance and or rejection of these rules thru an accepted rebuttal system.
- Allowing for independent agreements outside of these rules as they apply to repairs, provided such repairs meet AAR and FRA guidelines.
Rule B with the intent of:
- When specified in these rules all components, railcar construction and repairs must be reconditioned or performed in a facility that has current AAR M-1003 certification per AAR specifications.
- M-1003 is a set of quality controls that insure a consistent process across component refurbishment, railcar repair or refurbishment or new railcar construction.
- Driving compliance to the AAR and FRA rules and regulations as they pertain to repair of a freight railcar.
- Providing for a method to determine if there are any Early Warnings, Maintenance Advisories or Equipment Health Management System alerts or issues being noted by Railinc. Railinc is the operating arm of the AAR and is responsible for publication of rules, regulations, railcar equipment mechanical status, etc.
- Identifying railcar owners by railcar mark and or railcar registration.
Railcar Repair Classifications
Railcar repairs are classified by component and applicable test, removal, repair or replacement of that component. There are eight classifications of repair contained in the Field and Office Manuals that are specific to repair and refurbishment of railcar components. They are:
- Air Brake Equipment—Rule 2-15 concerning the testing of air brakes and a detailed review of air brake componentry compliance and wear.
- Couplers, Yokes, Draft Gear, Uncoupling Levers and Support Brackets—Rule 16 – 35 mainly focused on compliant parts and wear limits.
- Roller Bearings and Adapters—Rule 36 – 40 focused on gaging, wear limits and causes for renewal of roller bearings and roller bearing adapters.
- Wheels and Axles—Rule 41 – 45 with detailed descriptions of wear limits and types for wheels and axles.
- Truck Components—Rule 46 – 50 focusing on truck system performance, bolsters, side frames and springs and Rule 53 focusing on running boards, dome platforms, brake steps and crossover platforms.
- Sills—Rule 57 focusing on center sills and Rule 58 focusing on side sills and Rule 59 focusing on cushioned under-frame devices.
- Center Plates and Side Bearings—Rule 60 – 62 with emphasis on body center and side bearings and truck side bearings.
- General Repairs and Instructions—Rule 63-84 contain a menagerie of rules from Automatic Equipment Identification tag placement and requirements to restraint of loads.
There are an additional five classifications of rules that are specific to the (1) process of furnishing materials for repairs, (2) interchange of freight cars, (3) owners, handling or delivering line responsibility including contamination, (4) damage, disposition of damaged or destroyed equipment or cars requiring extensive repairs and (5) general regulations for billing.
Application of Rules and Regulations
It’s nice to know as a railcar owner or Lessee that the railroads have rules and regulations that govern repairs, but how are railcars identified that require repair and whose responsibility is it to identify repairs? Under Rule 1, Care of Freight Cars in the Field Manual section 1a. Each handling line is responsible for the condition of all cars on its line. To adhere to this requirement railroads generally do a minimal safety inspection at select points that roughly equate to inspecting of all railcars every one thousand miles, commonly referred to as the thousand-mile inspection. In addition to these thousand mile inspection points railroads have “hot box” detectors (to detect excessive heat in wheel bearings), and truck (truck hunting) and wheel (out of round) monitoring equipment at select locations on the railroad. The intent of these detectors is to provide for a safe and efficient operation of freight railcars on the railroad.
Repairs to empty railcars that require 16 labor hours or less can be done by the railroad without permission from the railcar owner. Repairs made that are less than 16 labor hours are generally classified as running repairs and are most often are those that concern the safe operation of the railcar. Repairs over 16 labor hours can be complete with the car owner permission by either the railroad or a private repair facility.
The Repair Network
The railcar repair network in the U.S., Canada and Mexico is extensive. Between railroads and private contract repair shops scattered across the country there are literally thousands of places a person can get a railcar repaired. Keep in mind the railroads have a process in place where if the repair is less than 16 man hours or is specific to the continued safe operation of the railcar in service they have the right to repair the railcar and send the car owner a bill for repairs. These railroad repair places generally coincide with thousand mile inspection points so a railcar that is inspected can be repaired and quickly placed back in service.
Private contract shops have grown out of need at various geographic locations around the country. For instance there are railcar repair shops in the Powder River Basin country of Wyoming that can accommodate ten plus unit coal trains for running repair and repair shops in the southeast U.S. that have room for no more than 50 railcars at a time serving Kaolin Clay and lumber freight business. As one can imagine private repair facilities generally specialize in either a car type, e.g. tank cars, general service freight cars or unit trains or in a type of work, running repairs (simple low man-hour work) or heavy back-shops specializing in complete refurbishment of a railcar.
Management of a Complex System
The railcar repair system is complex and as with all complex systems requires proactive management from knowledgeable individuals. There are literally hundreds of components and a myriad of reasons a repair can be made to a railcar. These repairs need to be managed proactively to ensure that the right repair is being made to the railcar and the right price is being charged for that repair.
Repair data is generally computer generated in what is called 500 byte format. There are a host of programs on the market that will take this data and generate information from it. The key is having the inherent knowledge to be able to interpret the information as to the application of the rules to the repair.
From a haulers’ perspective or from a private contractor or municipality that contracts with a rail transporter its important to first understand that there are specific railcar repair rules that apply to a waste-by-rail transport operation. Second, it’s important to understand that there are repair networks in place that can and will repair railcars in various states of disrepair. Finally, it’s important to either become knowledgeable of the railcar repair rules and regulations or find someone that is and ask for help.
Darell Luther is president of Forsyth, MT-based Tealinc Ltd., a rail transportation solutions and railcar leasing company. Darell’s career includes positions as president of DTE Rail and DTE Transportation Services Inc., Fieldston Transportation Services LLC, managing director of coal and unit trains for Southern Pacific Railroad and directors positions in marketing, fleet management and integrated network management at Burlington Northern Railroad. Darell has more than 24 years of rail, truck, barge and vessel transportation experience concentrated in bulk commodity and containerized shipments. He has received many exploratory calls inquiring how to ship various waste streams by rail and would welcome your inquiry as well.Darell can be reached at (406) 347-5237, via e-mail at [email protected] or visit www.tealinc.com.