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NTSB recommends better placement of buffer cars

NTSB gives three recommendations to trade groups and federal agencies governing rail movements of hazardous materials

NTSB issued several safety recommendations regarding the placement of buffer cars. (Photo: Jim Allen/FreightWaves)

The freight rail industry needs to reconsider where it places buffer cars and tank cars on trains carrying hazardous materials in order to better protect train crew members and reduce the severity of a potential accident, according to recommendations from the National Transportation Safety Board concerning two accidents in April 2019 and February 2020.

NTSB’s safety recommendations come from its investigations into two incidents involving breached U.S. Department of Transportation-111 tank cars on high-hazard flammable trains. 

On April 24, 2019, a Union Pacific (NYSE: UNP) train carrying denatured ethanol derailed in Fort Worth, Texas, and three tank cars were breached. The breached tank cars, which included one “severely damaged” legacy DOT-111 tank car, released 65,270 gallons of denatured ethanol, which ignited and formed pool fires. No individuals were hurt.

And on Feb. 13, three locomotives, one buffer car and four tank cars derailed a CSX (NASDAQ: CSX) ethanol unit train near Draffin, Kentucky. That train had one buffer car at the head of the consist and three at the train’s rear, with 96 denatured ethanol cars following the head buffer car. A consist is a sequence or group of railcars making up a train.


“The severity of the Draffin, Kentucky, and Fort Worth, Texas, accidents could have been mitigated had the U.S. Department of Transportation-111 tank cars been placed in locations within the train where they were less likely to derail or to sustain accident damage,” NTSB said in its report. 

Using industry guidelines and recommended practices on placing DOT-111 tank cars in lower risk positions on the train can be “the most expeditious means for shippers and carriers of high-hazard flammable trains to achieve the safety benefits of fewer breached tank cars in derailments,” NTSB continued. It also said that a single buffer car doesn’t provide sufficient distance from train crews.

“This is not the first time NTSB has issued recommendations regarding the use of buffer cars to reduce the risks of hazardous materials release to train crews,” said Robert Hall, NTSB director of railroad, pipeline and hazardous materials. “We believe that it is imperative that these recommendations be implemented to prevent the potential for a catastrophic event.”

To address these findings, NTSB recommended the following: 


  • The Association of American Railroads, the American Short Line and Regional Railroad Association and the Renewable Fuels Association should “develop and adopt guidelines and recommended practices for the systematic placement of the most vulnerable tank cars in high hazard flammable trains,” such as unmodified DOT-111 tank cars, “in positions of trains where they are least likely to derail or to sustain mechanical damage from the effects of trailing tonnage or collision in an accident.”
  • The Pipeline and Hazardous Materials Safety Administration (PHMSA) should evaluate “the risks posed to train crews by hazardous materials transported by rail, determine the adequate separation distance between hazardous materials cars and locomotives and occupied equipment that ensures the protection of train crews during both normal operations and accident conditions,” and it should collaborate with the Federal Railroad Administration (FRA) to revise federal code related to this recommendation. 
  • The FRA should “evaluate the risks posed to train crews by hazardous materials transported by rail, determine the adequate separation distance between hazardous materials cars and locomotives and occupied equipment that ensures the protection of train crews during both normal operations and accident conditions, and collaborate” with PHMSA to revise federal codes. 

“The recommendation requires all trains have a minimum of five non-placarded cars between any locomotive or occupied equipment transporting hazardous materials, regardless of train length and consist,” NTSB said.

NTSB said links to the Draffin and Fort Worth accidents reports and other publicly released information about these investigations are available here.

The Brotherhood of Locomotive Engineers and Trainmen (BLET) praised the NTSB recommendations.

“As we have said for years, a change in the rule would require minor, easily accommodated operational changes and not the need for some expensive technology,” said BLET President Dennis Pierce. “Continuing to allow the railroads to self-regulate puts the lives of train crews at risk and could lead to a wholly unnecessary loss of life.”

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Joanna Marsh

Joanna is a Washington, DC-based writer covering the freight railroad industry. She has worked for Argus Media as a contributing reporter for Argus Rail Business and as a market reporter for Argus Coal Daily.