With a final rulemaking by the Department of Transportation (DOT) in May 2015, which was modified by a subsequent Act of Congress in December 2015, the Department and Congress set new safety rules for rail transportation of flammable liquids. Although primarily targeting crude oil and ethanol shipments, the rule applies to shipment of all Class 3 flammable liquids and thus to methyl methacrylate (MMA). MPA had commented on the Department’s proposed rules, expressing concern about the need for such rules given the methacrylate industry’s voluntary adoption of higher-safety tank cars, as well as the foreshortened and likely unrealistic timeline proposed for implementing required retrofits (or obtaining new tank cars built to the new DOT-117 specifications). DOT’s final rule was not adequately responsive to such concerns. Congress stepped in with provisions in the” Fixing America’s Surface Transportation Act” (FAST Act) which modified the DOT rule. For Packing Group II substances such as MMA, improved tank cars must be used for transport after May 1, 2029, consistent with MPA’s comments requesting an extended period for implementation of the new rules. DOT can extend this deadline by two years if it determines there is insufficient shop capacity to meet the 2029 deadline. Further, in lieu of meeting the full DOT-117 standards, retrofitted tanks cars may comply with DOT-117R standards, which many tanks cars in MMA service already meet. The voluntary adoption of tank car enhancements by MMA members has contributed to an outstanding safety record for rail transportation of MMA.

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