Utilization of Association of American Railroads' Tank Car Approvals

This is in response to your December 19, 1997 letter that included a request for an explanation of the procedures that allow Federal inspectors to obtain and utilize Association of American Railroads' (AAR) tank can approvals during their inspection.

The procedure for tank car approval requires submission in a prescribed form, including detailed prints, to the AAR for approval. Approval or rejection is based on action taken by the AAR's Tank Car Committee. The Committee approves an application if, in the opinion of the Committee, such tanks or equipment conform to the Department of Transportation's regulations. The Committee performs a designated third-party approval function that helps ensure that Federal regulations are met. Irrespective of the Committee's actions, the owner (offeror) of the tank car remains responsible for ensuring compliance with the applicable specifications.

Federal regulations and industry requirements specify that the owner of a tank car shall maintain a copy of the certificate of construction which certifies that the tank car identified in the certificate conforms to the specification identified. An approval is part of a certificate of construction. The regulations also require the transfer of certificates upon changes in ownership. Accordingly, Federal inspectors obtain copies of certificates of construction and related papers, including detailed prints, from tank car owners and not the AAR.

If you have any questions, please contact me or Mr. Bill Vincent, Director, Office of Policy and Program Support, at (202)366-4831.