On July 14, 2016, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and Federal Railroad Administration (FRA) released a notice of proposed rule-making for public comment. The Proposed Rule substantially increases the oil spill response planning and reporting requirements for railroads transporting High-Hazard Flammable Trains (HHFT).
New Planning Requirements
The Proposed Rule requires submission of comprehensive Oil Spill Response Plans (OSRP) for trains consisting of 20 or more loaded tank cars in a block or 35 or more loaded tank cars total, and prohibits the transport of oil without OSRP approval by FRA. Additionally, the rule proposes strengthening comprehensive OSRP by including:
- Area response plans for regional response zones based on HHFT routing analysis to ensure availability of personnel and equipment in different route segments
- Certification and documentation of trained personnel and Oil Spill Response drills
- OSRP updates every 5 years, when conditions change, or after a discharge
New Reporting Requirements
In addition, the Proposed Rule requires railroads to report the following information to state and tribal authorities monthly:
- HHFT Routes and an estimated number of trains travelling per county per week
- Materials shipped and emergency response information
- Point of contact
These changes represent a substantial increase in railroad reporting and planning.
How Gradient Can Help
- Review current OSRPs for compliance with the legislation
- Develop regional and national contract laboratory programs
- Provide sampling SOPs using national and regional accepted practices
- Help develop sampling training programs for responders
- Develop Data Quality Objects that support response, remediation and potential litigation needs
Read about the Proposed Rule here.
Read about Gradient’s Data Integrity in Accidental Release Response Services here.
Connect to Gradient’s Website here.