U.S. Department of Transportation and Transport Canada - Important Update on Class 3 Flammable Liquid Tank Car Phase-Out
The United States and Canadian governments have enacted legislation that mandates the phase-out of specific tank cars used for the rail transportation of flammable liquids, 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, all jacketed and unjacketed legacy Class 111 tank cars, along with jacketed and unjacketed enhanced Class 111 tank cars (also referred to as CPC-1232 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 two countries regarding the phase-out dates for these regulations:
- No shipments of Class 3 unrefined petroleum products, ethanol, or flammable liquids in Packing Group I will be permitted into the United States 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.
DOT-111 Tank Car Phase-Out Schedule (Transport not authorized on or after) | ||||||
Commodity | Country | DOT 111 Non-Jacketed | DOT 111 Jacketed | CPC-1232 Non-Jacketed | CPC-1232 Jacketed | DOT 117 (J, P, R) |
Unrefined Petroleum Products (Crude Oil) | US | Prohibited | May 1, 2025 | Authorized | ||
Canada | Prohibited | May 1, 2025 | ||||
Ethanol (Alcohols NOS) | US | Prohibited | May 1, 2025 | |||
Canada | Prohibited | May 1, 2025 | ||||
Class 3 Packing Group I | US | May 1, 2025 | ||||
Canada | May 1, 2025 | |||||
Class 3 Packing Groups II and III | US | May 1, 2029 | ||||
Canada | May 1, 2025 |
As outlined in the requirements for both jurisdictions mentioned above, BNSF will start rejecting any billing for tank cars (whether loaded or containing empty residue) that are subject to the May 1st phase-out, beginning April 24th, 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 the Universal Machine Language Equipment Register (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.
If you have any questions, please contact your BNSF marketing representative.
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