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USDOT, TC: Only DOT-117 Tank Cars Allowed After May 1

DOT-117 (TC-117 in Canada). DOT-117Rs are rebuilds of DOT-111s. Transport Canada illustration.

The U.S. and Canadian governments have enacted legislation updating the phaseout date of all tank cars used for the rail transport of flammable liquids, except DOT-117J (new) and DOT-117R (rebuilt) cars, to May 1, 2025. The phaseout is applicable to both loaded and residue shipments.

United States

According to U.S. Department of Transportation Hazardous Materials Regulations, § 173.242, all jacketed and unjacketed legacy Class 111 tank cars, as well as jacketed and unjacketed enhanced Class 111 tank cars (also referred to as CPC-1232 tank cars), will be prohibited from importing, offering for transport, handling, or transporting unrefined petroleum products, ethanol, and Class 3 flammable liquids in Packing Group I, effective May 1, 2025.

Canada

Under Transport Canada’s Containers for Transport of Dangerous Goods by Rail standard, Section 10.5.6, these same tank cars will be barred from importing, offering for transport, handling, or transporting Class 3 flammable liquids in Packing Groups I, II and III, effective May 1, 2025.

International Shipments

There is no reciprocity between the U.S. and Canada regarding the phaseout dates for the following regulations:

  • No shipments of Class 3 unrefined petroleum products, ethanol, or flammable liquids in Packing Group I will be permitted into the U.S. on or after May 1, 2025, regardless of the shipment’s origin.
  • No shipments of Class 3 flammable liquids in Packing Groups I, II, or III will be allowed into Canada on or after May 1, 2025, regardless of the shipment’s origin.

In a notice to customers, BNSF said it “will start rejecting any billing for tank cars (whether loaded or containing empty residue) that are subject to the May 1 phaseout, beginning April 24, 2025. This policy will apply to any shipments that originate, are destined for, or transit through BNSF’s network. BNSF will utilize data elements from UMLER to determine whether tank cars comply with the regulations. Please ensure that your data in UMLER is current to prevent your cars from being rejected.”