Your Questions Answered: DOT-111 Ethanol Phase-Out
Written by Marybeth Luczak, Executive Editor
The Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Railroad Administration (FRA) have released a “Frequently Asked Questions” document on implementing the upcoming phase-out of DOT-111 specification tank cars from ethanol service.
PHMSA and FRA on April 25 reported receiving “numerous requests for clarification” from rail carriers and shippers, and compiled a document to inform them (download below).
Following are their answers to five key questions:
1. What is the phase-out schedule for ethanol transportation in DOT-111 specification tank cars?
“DOT-111 specification tank cars (jacketed and non-jacketed) are not authorized for ethanol transportation on or after May 1, 2023. DOT-111 specification tank cars built to the CPC-1232 standard (non-jacketed) are not authorized for ethanol transportation on or after July 1, 2023. DOT-111 specification tank cars built to the CPC-1232 standard (jacketed) are not authorized for ethanol transportation on or after May 1, 2025.”
2. What is “ethanol” for purposes of the phase-out requirement for DOT-111 specification tank cars?
“For purposes of the phase-out requirement for DOT-111 specification tank cars, ‘ethanol’ means ethanol described under an appropriate proper shipping name—to include: ‘UN1170, Ethanol or Ethyl alcohol or Ethanol solutions or Ethyl alcohol solutions’; ‘NA1987, Denatured alcohol’; ‘UN1987, Alcohols, n.o.s.’; or ‘UN3475, Ethanol and gasoline mixture or Ethanol and motor spirit mixture or Ethanol and petrol mixture, with more than 10% ethanol.’”
3. A DOT-111 specification tank car is filled with ethanol prior to the applicable phase-out date. Can this tank car be offered for transportation after the applicable phase-out date?
“No. A tank car filled with ethanol prior to the applicable phase-out date may not be offered for transportation after the applicable phase-out date.”
4. A DOT-111 specification tank car loaded with ethanol is offered for transportation and accepted by a rail carrier before the applicable phase-out date. Can this tank car remain in transportation after the phase-out date until it reaches its final destination?
“Yes. A tank car subject to the phase-out may remain in transportation after the phase-out date until it reaches its final destination, provided it was loaded with ethanol and accepted by a rail carrier prior to the applicable phase-out date.”
5. Can a DOT-111 specification tank car that contains ethanol “residue” be offered for transportation after the applicable phase-out date?
“Yes. However, transportation of a DOT-111 specification tank car containing ethanol residue after the applicable phase-out date must be authorized via a One Time Movement Approval (OTMA) issued by the FRA in accordance with § 174.50. Specifically, the OTMA-3 process will apply to DOT-111 specification tank cars containing ethanol residue moving to a designated tank car facility for cleaning or other disposition. Further information on the OTMA application process is available on the FRA’s website here: https://railroads.dot.gov/elibrary/hmg-127-one-time-movement-approval-procedures-0.”
PHMSA and FRA noted that the document “is considered guidance according to DOT Order 2100.6A (June 7, 2021). Except when referencing laws, regulations, policies, or orders, the contents of these FAQs do not have the force and effect of law and is not meant to bind the public in any way. These FAQs are intended only to provide information to the public regarding existing requirements under the Hazardous Materials Regulations. This document does not revise or replace any previously issued guidance. For further information on the requirements for transporting flammable liquids in DOT specification tank cars, see final rule HM-251C.”
