otma-3 - Bourque Logistics

Section 1
Introduction and Overview
©2014 Bourque Data Systems, Inc.
1
One
Time
Movement
Approval
©2014 Bourque Data Systems, Inc.
2
• Since 1996 the Federal Railroad Administration (FRA) has
been authorized to issue OTMA’s for bulk packages (tank
cars) that no longer conform to Hazardous Materials
Regulations (49 CFR Parts 171-180)
• In 2000, that authority was expanded to cover all bulk
packages (e.g., covered hopper cars, gondolas, portable
tanks, etc.) of hazardous materials.
©2014 Bourque Data Systems, Inc.
3
Categories of OTMA‘s
OTMA – 1 Traditional
OTMA – 2 Overloaded condition
OTMA – 3 Standing approval
©2014 Bourque Data Systems, Inc.
4
OTMA - 3
•
•
•
•
•
STANDING APPROVAL FOR SPECIFIC CONDITIONS
APPLIES TO EMPTY/CLEAN, RESIDUE AND LOADED RAILCARS
DOES NOT APPLY TO PIH (POISON INHALATION HAZARD)
APPLICATION CAN BE MADE VIA EMAIL NOTIFICATION
CAR CAN MOVE IMMEDIATELY AFTER CONFIRMATION OF EMAIL
NOTIFICATION IS RECEIVED
©2014 Bourque Data Systems, Inc.
5
OTMA - 2
•
•
•
•
APPLIES TO RAILCARS OVERLOADED BY WEIGHT
CAR CANNOT MOVE UNTIL APPROVAL IS RECEIVED FROM FRA
ROOT CAUSE ANALYSIS IS USUALLY REQUIRED WITHIN 60 DAYS
NO MOVEMENT APPROVALS WILL BE GIVEN FOR CARS
OVERLOADED BY VOLUME
©2014 Bourque Data Systems, Inc.
6
OTMA - 1
•
APPLIES TO ALL OTHER CONDITIONS NOT SPECIFICALLY
COVERED BY OTMA-2 OR OTMA-3
•
REQUIRES WRITTEN APPROVAL FROM FRA BEFORE RAILCAR CAN
BE MOVED
•
ROOT CAUSE ANALYSIS IS USUALLY REQUIRED WITHIN 90 DAYS
©2014 Bourque Data Systems, Inc.
7
IN SUMMARY, ANY RAIL CAR BUILT TO A DEPARTMENT OF
TRANSPORTATION SPECIFICATION THAT NO LONGER
CONFORMS TO SPECIFICATION REQUIRES AN OTMA TO
MOVE TO A REPAIR SHOP OR DISMANTLER
©2014 Bourque Data Systems, Inc.
8
SECTION 2
PREPARING A RAILCAR FOR
UNDER OTMA GUIDANCE
MOVEMENT
©2014 Bourque Data Systems, Inc.
9
•
•
•
•
•
CLEARLY IDENTIFY THE DEFECT
TAG OR MARK THE DEFECTIVE PART(S)
SECURE SECONDARY CLOSURES
ASSURE CAR IS IN A LEAK FREE CONDITION
APPLY “HOME SHOP” DECALS OR STENCILING NEAR REPORTING
MARKS ON EACH SIDE OF CAR
•
INSPECT TO INSURE CAR IS OTHERWISE SAFE TO MOVE (PRE-TRIP
INSPECTION)
©2014 Bourque Data Systems, Inc.
10
•
DETERMINE SUITABLE REPAIR FACILITY(S)
•
IT MAY BE NECESSARY TO MOVE THE CAR TO MULTIPLE FACILITIES
TO ACCOMPLISH REPAIRS SUCH AS A SEPARATE CLEANING FACILITY
OR RETURNING TO LOADING POINT OF TRANS-LOADING BEFORE
SENDING CAR TO REPAIR SHOP
•
CHECK WITH FACILITIES PRIOR TO SUBMITTING APPLICATION TO
VERIFY THAT THEY CAN COMPLETE THE NECESSARY REPAIRS
©2014 Bourque Data Systems, Inc.
11
•
DETERMINE ROUTE TO SELECTED FACILITIES
•
•
•
CONTACT CARRIERS TO ASSURE THEY WILL ACCEPT THE RAILCAR
RAILROADS ARE NOT REQUIRED TO ACCEPT DEFECTIVE RAILCARS
SELECTED ROUTE LISTED ON OTMA APPLICATION MUST
INCLUDE COMPLETE ROUTING TO ALL FACILITIES IF MORE THAN
ONE FACILITY IS NECESSARY TO COMPLETE REPAIR
©2014 Bourque Data Systems, Inc.
12
•
CLEARLY
•
•
IS
IDENTIFY THE DEFECT
IT A VALVE LEAKING?
•
IF
•
WHICH VALVE
VALVE, ETC.?
IS
•
•
•
SO, WHERE IS IT LEAKING, THROUGH THE VALVE STEM, THROUGH THE BALL,
UNDER THE MOUNTING FLANGE?
IS LEAKING, SAFETY VALVE, TOP UNLOADING VALVE, BOTTOM
IT A BREACH IN THE TANK SHELL OR A FRACTURED SILL?
IF
SO, WHERE IS THE DEFECT/FRACTURE?
HOW
IS
LONG IS THE FRACTURE?
IT A TRANSVERSE FRACTURE OR A CIRCUMFERENTIAL FRACTURE?
©2014 Bourque Data Systems, Inc.
13
TAG DEFECTIVE PART(S)
(DEFECTIVE LOAD VALVE)
©2014 Bourque Data Systems, Inc.
14
DEFECTIVE BOTTOM OUTLET
VALVE (BOV)
©2014 Bourque Data Systems, Inc.
15
DEFECTIVE MAIN PLATE
GASKET
©2014 Bourque Data Systems, Inc.
16
DEFECTIVE EDUCATION
(SIPHON) PIPE ASSEMBLY
©2014 Bourque Data Systems, Inc.
17
SECURE SECONDARY CLOSURES
©2014 Bourque Data Systems, Inc.
18
AFTER ASSURING CAR IS LEAK
FREE, APPLY “HOME SHOP”
DECALS NEAR REPORTING
MARKS
©2014 Bourque Data Systems, Inc.
19
SECTION 3
DETERMINING OTMA LEVEL
©2014 Bourque Data Systems, Inc.
20
CONSULT THE 9 PAGE
HAZARDOUS MATERIAL
GUIDANCE DOCUMENT
HMG-127 FOR
DETAILED INSTRUCTIONS
TO DETERMINE OTMA
LEVEL OR CONTACT YOUR
LOCAL FRA FIELD
INSPECTOR FOR
GUIDANCE
©2014 Bourque Data Systems, Inc.
21
The OTMA Guidance document
HMG-127, Revision 3, includes
a 5 page flow chart to help
determine the correct OTMA
level.
©2014 Bourque Data Systems, Inc.
22
PAGE 1
LISTS THE
VARIOUS CONDITIONS
OF THE DEFECTIVE
TANK CAR.
•
•
•
•
LOADED
RESIDUE
CLEAN
NON-REGULATED
©2014 Bourque Data Systems, Inc.
23
FLOW CHART FOR
LOADED CARS
©2014 Bourque Data Systems, Inc.
24
FLOW CHART FOR
RESIDUE CARS
©2014 Bourque Data Systems, Inc.
25
FLOW CHART
FOR CLEAN CARS
©2014 Bourque Data Systems, Inc.
26
FLOW CHART
FOR CARS
CARRYING NONREGULATED
COMMODITIES
©2014 Bourque Data Systems, Inc.
27
OTMA 1 & 2
SUMMARY
APPLICATION
INSTRUCTIONS
©2014 Bourque Data Systems, Inc.
28
REQUESTS FOR OTMA’S 1
& 2 ARE TO BE MADE ON
THE FRA’S MOVEMENT
APPROVAL INFORMATION
FORM. COMPLETED FORMS
CAN BE EMAILED TO
[email protected] OR
FAXED TO 202-493-6478
ANY
PHOTOS, SCALE
TICKETS AND ANY OTHER
SUPPORTING DOCUMENTS
SHOULD ALSO ACCOMPANY
THE APPLICATION
©2014 Bourque Data Systems, Inc.
29
AN OTMA-3
REQUEST
CAN BE MADE BY
SENDING AN EMAIL WITH
THE APPROPRIATE
INFORMATION TO
[email protected]
THE
REQUIRED
INFORMATION FORMAT
CAN BE FOUND ON PAGE
6
OF
HMG-127
•
•
•
•
MOVING PER 49CFR 174.50 (OTMA-3)
•
•
•
•
•
•
COMMODITY NAME AND UN/NA NUMBER:
•
•
DESTINATION (CITY, STATE):
CAR NUMBER(S):
DOT SPECIFICATION:
LOADED OR RESIDUE OR CLEANED AND
PURGED:
GRANTEE:
CONTACT NAME:
CONTACT TELEPHONE/EMAIL:
DESCRIPTION OF DEFECTIVE CONDITION:
PRESENT LOCATION (FACILITY/RAILROAD
NAME, CITY, STATE):
ROUTING:
©2014 Bourque Data Systems, Inc.
30
A
CAR OR CARS THAT ARE TO MOVED ON
AUTHORITY OF AN OTMA-3 CAN MOVE AS SOON
AS A CONFIRMATION EMAIL IS RECEIVED FROM
THE FRA.
©2014 Bourque Data Systems, Inc.
31
•
•
IDENTIFY
SECURE
•
•
•
•
DEFECT
RAILCAR
STOP
ALL LEAKS
APPLY
SECONDARY CLOSURES
APPLY “HOME SHOP”
PREFORM
STENCILS
PRE-TRIP INSPECTION
©2014 Bourque Data Systems, Inc.
32
•
•
•
CONFIRM
THAT AFFECTED RAILROADS WILL ACCEPT RAILCAR
CONFIRM
THE REPAIR FACILITIES WILL ACCEPT RAIL CAR
DETERMINE OTMA
•
•
CONSULT HMG-127
APPLY
•
LEVEL
FOR
AND FLOW CHARTS
OTMA
INCLUDE
ANY SUPPORTING DOCUMENTATION AND PHOTOS
©2014 Bourque Data Systems, Inc.
33
•
COMPLY
WITH ANY ADDITIONAL REQUIREMENTS AS
LISTED IN THE
•
PROVIDE
OTMA
APPROVAL
FOLLOW UP ROOT CAUSE ANALYSIS TO
PRESCRIBED TIME FRAME.
FRA
IN
©2014 Bourque Data Systems, Inc.
34
•
THE FRA
HAS THE AUTHORITY TO LEVY FINES FOR NON-
COMPLIANCE
•
•
TYPICAL
THE FRA
FINES BEGIN AT
$5000
IS NOT IN THE BUSINESS OF ISSUING FINES,
THEY ARE IN THE BUSINESS OF ENFORCING COMPLIANCE,
SO CONTACT YOU LOCAL FIELD INSPECTOR OR THE
WASHINGTON
WITH ANY QUESTIONS!!!
FRA
©2014 Bourque Data Systems, Inc.
IN
35

Download Report