Salco Products First Quarter 2021 Implementation of RSI-100
December 1, 2020
On October 8, 2019 the Department of Transportation (DOT), Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a letter to the Railway Supply Institute’s (RSI), Michael O’Malley clarifying that tank car component manufacturers do not meet the definition of a “tank car facility” because they are not making a “representation” of tank car conformity as defined in 49 CFR 179.2*.
As a direct result of PHMSA’s interpretation FRA has refocused their enforcement actions on tank car builders and repair facilities to comply with 49 CFR 179.7 (4), (5), and (f) as defined below:
- (4) Procedures to ensure that the fabrication and construction materials received are properly identified and documented. (Note: this applies to purchasing/subcontracting and incoming inspection. If your procedures do not address your incoming inspection requirements, the FRA violation will reference this section)
- (5) A description of the manufacturing, repair, inspection, testing, and qualification or maintenance program, including the acceptance criteria, so that an inspector can identify the characteristics of the tank car and the elements to inspect, examine, and test at each point. (Note: This applies to Production, Inspection, and Test Planning (PITP), If your PITP doesn’t identify how you meet this, the FRA violation will reference this section)
- (f) No tank car facility may manufacture, repair, inspect, test, qualify or maintain tank cars subject to requirements of this subchapter, unless it is operating in conformance with a quality assurance program and written procedures required by paragraphs (a) and (b) of this section. (Note: If a facility identifies their incoming inspection criteria and are not following them, the FRA violation will reference this section)
As a result of this RSI changed the direction of the development of RSI-100, which began as a voluntary standard as industry’s proposed alternative to facility certification, prior to the issuance of the October 8, 2019 clarification letter from PHMSA. RSI now offers RSI-100 as a guidance document for AAR tank car facilities to enhance purchase orders and the incoming inspection of tank car components as detailed within this standards Appendix A. The RSI task force has a few additional changes to make before it is ready for industry use. The current version of the standard is posted. Interested parties are able to download it from RSI’s website.
Salco’s path forward:
A great many of our tank car parts customers will be requiring their parts suppliers to implement RSI-100’s requirements and supply the necessary documentation required by its Appendix A. Salco has been an integral part of the development of RSI-100 and as a standard practice will be fully implementing its requirements around the end of the first quarter, 2021. For those customers who decide not to implement RSI-100 into their company’s requirements, we will still supply the same documentation, only the noted Product Certification Plans (PCPs) on the attached Certificate of Conformance (COC) will not be checked. In those cases, we will check the “N/A” box.
Meeting our tank car parts customers documentation needs is a partnership. That partnership can be seamless when we know those requirements. Part of our internal process is to first perform a contract review to assure the purchase orders we receive define all requirements. General statements such as: “Acceptance and Rejection Criteria per FRA Requirements”, or “Meets all Quality Requirements of Applicable Specifications” are too vague and do not accurately convey customer’s requirements. Nobody can guess a customer’s requirements unless they are defined, that is where we need your assistance to help us meet them.
As we work to implement RSI-100 into our quality management system we will keep our valued customers informed of any new developments. If any of you have any questions or wish to discuss the implementations of RSI-100 on your organization, please feel free to contact me at 630.512.7595 or [email protected].
Sincerely,
Thomas E. DeLafosse
*It should be noted as a matter of clarification that the Association of American Railroads (AAR) still requires facility certification for component manufactures that manufacture and assemble tank car valves and fittings, as defined in AAR’s Manual of Standards and Recommended Practices (MSRP), Section C-III, Appendix B.
Read the full RSI-100 journey Here