HAZARDOUS 

MATERIALS RAIL 

SHIPMENTS

A Review of 

Emergency Response 

Information in 

Selected Train 

Documents

GAO-17-130

Report to Congressional Committees

December 2016

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-130, a report to 

congressional committees 

December 2016

HAZARDOUS MATERIALS RAIL SHIPMENTS

A Review of Emergency Response Information in 

Selected Train Documents

What GAO Found

To help emergency responders safely handle rail accidents involving hazardous 

materials, selected railroads transporting hazardous materials typically carry two 

sources of information: the Department of Transportation’s (DOT) Emergency 

Response Guidebook (ERG) and information in the trains’ documents. Federal 

Hazardous Material Regulations require railroads and other hazardous material 

transporters to carry emergency response information that describes immediate 

hazards to health and risks of fire or explosion, among other things. 

Representatives from all 18 railroads GAO interviewed told us that they carry the 

ERG on their trains. According to DOT officials, the ERG’s use is not required by 

regulation, but the rail industry views it as a national standard for emergency 

response information. Our review of selected train documents showed that they 

always have a basic description of each hazardous material being transported, 

including the identification number and proper shipping name, as well as an 

emergency response telephone number. Six of the 7 Class I railroads and 5 of 

the 11 selected Class II and III railroads also included emergency response 

information in these documents. According to four emergency response 

associations, in the first 30 minutes after a rail incident, emergency responders 

primarily use the train documents to locate and identify hazardous materials and 

use the ERG to identify potential response actions. 

Emergency Response Information Used in the First 30 Minutes of a Rail Accident

GAO found that the emergency-response information in the ERG and the GAOreviewed train documents of the selected railroads were generally similar, but 

differed somewhat in the level of specificity and type of information. For the 72 

frequently shipped hazardous materials GAO selected, the train documents at 

times described hazards, mitigation measures, and protective-clothing 

requirements more specifically than the ERG. The ERG provided more detail on 

evacuation distances. However, for 6 selected hazardous materials, the 

recommended evacuation distances in the ERG differed from the supplemental

emergency response information which is provided by the Association of

American Railroads’ (AAR) Hazardous Materials Emergency Response 

Database. AAR decided in August 2016 to discontinue the database, removing 

the potential for discrepancies between the ERG and the supplemental 

emergency response information from AAR going forward.

View GAO-17-130. For more information, 

contact Susan Fleming at (202) 512-2834 or 

flemings@gao.gov. 

Why GAO Did This Study

In November 2012, a train derailed in 

Paulsboro, New Jersey, releasing 

about 20,000 gallons of vinyl chloride, 

a hazardous material. The National 

Transportation Safety Board (NTSB) 

found, among other issues, that the

supplemental information in the train’s 

documents on responding to 

emergencies involving vinyl chloride

was inconsistent with and less

protective than emergency response 

guidance in the ERG. Congress 

included a provision in statute for GAO 

to evaluate the differences between 

the emergency response information 

carried by trains transporting 

hazardous materials and the ERG

guidance. This report examines (1) 

what emergency response information 

is carried on trains by selected 

railroads transporting hazardous 

materials and how responders use it, 

and (2) how selected railroads’ 

supplemental emergency response 

information compares to information in 

the ERG. 

GAO reviewed the ERG and other 

relevant literature and met with DOT 

and NTSB officials, among others. 

GAO interviewed all 7 larger Class I 

railroads and 11 smaller Class II and III 

railroads that carried hazardous 

materials in 2015. GAO compared the 

supplemental emergency response 

information with ERG information for 

72 frequently shipped hazardous 

materials from a nonprobability sample 

of train documents provided by 10 of

the 18 selected railroads. 

What GAO Recommends

GAO is not making recommendations.

DOT and NTSB provided technical 

comments, which GAO incorporated. 
Page i GAO-17-130 Hazardous Materials Rail Shipments

Letter 1

Background 5

Selected Railroads Carry the ERG and Train Documents; 

Responders Use This Information and Additional Sources to 

Determine How to Take Action 11

Supplemental Emergency Response Information on Reviewed 

Train Documents Was Generally Similar to ERG Information 19

Agency Comments 24

Appendix I Objectives, Scope, and Methodology 26

Appendix II GAO Contact and Staff Acknowledgments 31

Table

Table 1: Comparison of General Content of the Emergency 

Response Guidebook (ERG) and Supplemental 

Emergency Response Information in Selected Train 

Documents 21

Figures

Figure 1: Initial Response to a Rail Accident Involving Hazardous 

Materials 8

Figure 2: Sample of Sections of the Department of 

Transportation’s Emergency Response Guidebook 10

Figure 3: Information Found in Reviewed Train Documents 

Regarding the Position and Content of Rail Cars and 

Emergency Response for Specific Hazardous Materials 13

Figure 4. Timeline of When Specific Emergency Response 

Information is Used in a Rail Accident 17

Contents
Page ii GAO-17-130 Hazardous Materials Rail Shipments

Abbreviations

ASLRRA American Short Line and Regional Railroad Association

AAR Association of American Railroads 

DOT Department of Transportation 

ERG Emergency Response Guidebook 

FAST Act Fixing America’s Surface Transportation Act

FRA Federal Railroad Administration 

HMR Hazardous Materials Regulations 

NIOSH National Institute for Occupational Safety and Health

NTSB National Transportation Safety Board 

PHMSA Pipeline and Hazardous Materials Safety Administration

WISER Wireless Information System for Emergency Responders 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-130 Hazardous Materials Rail Shipments

441 G St. N.W.

Washington, DC 20548

December 2, 2016

The Honorable John Thune

Chairman

The Honorable Bill Nelson

Ranking Member

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Bill Shuster

Chairman

The Honorable Peter A. DeFazio

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

According to AAR, freight railroads operating in the United States 

transported approximately 2.35-million carloads of hazardous materials in 

2015.1 In November 2012, a train derailed while traveling over a bridge in

Paulsboro, New Jersey, releasing about 20,000 gallons of vinyl chloride, 

a hazardous material and human carcinogen.2 Damage estimates were 

$451,000 for equipment and about $30 million for emergency response 

and remediation. During investigation of the incident, the National 

Transportation Safety Board (NTSB) found, among other issues, that the 

supplemental emergency response information for handling vinyl chloride 

that was contained in the train documents was inconsistent with and less 

protective than emergency response guidance in the Emergency 

Response Guidebook (ERG), a manual published by the Department of 

Transportation (DOT), that emergency responders refer to when 

responding to hazardous materials incidents. NTSB concluded that such 

railroad-provided supplemental emergency response information that 

 1

Hazardous materials are a group or class of materials that the Secretary of 

Transportation determines may pose an unreasonable risk to health and safety or property 

when transported in commerce in a particular amount and form. 49 U.S.C. § 5103(a).

2

According to the Environmental Protection Agency, short-term exposure to high levels of 

vinyl chloride, which is used to make plastic and vinyl products, in air has resulted in 

central nervous system effects, such as dizziness, drowsiness, and headaches in 

humans. Cancer is a major concern from exposure to vinyl chloride via inhalation, as vinyl 

chloride exposure has been shown to increase the risk of a rare form of liver cancer in 

humans.

Letter
Page 2 GAO-17-130 Hazardous Materials Rail Shipments

deviates from nationally recognized ERG information has the potential to 

confuse emergency responders faced with making timely decisions in 

response to hazardous materials releases, including decisions regarding 

distances from a release to protect people from vapors resulting from 

spills involving hazardous materials.3 Recent rail accidents, such as those 

in Mosier, Oregon, and Lac Mégantic, Quebec, have led to questions 

about the safety of rail shipments of hazardous materials and the 

resources and information available to local emergency responders in 

rural areas to allow them to take swift protective actions in the immediate 

aftermath of a serious accident.

Within DOT, the Pipeline and Hazardous Materials Safety Administration 

(PHMSA) has lead responsibility for ensuring the safe movement of 

hazardous materials across all transportation modes by issuing and 

enforcing safety regulations—including requirements for carriers and

shippers, including railroads—to carry certain types of emergency 

response information. PHMSA coordinates with the Federal Railroad 

Administration (FRA) in developing hazardous materials transportation 

regulations and interpreting how they apply to rail transportation and FRA 

enforces these regulations.

The Fixing America’s Surface Transportation (FAST) Act included a 

provision for GAO to evaluate the differences between the emergency 

response information carried by train crews transporting hazardous 

materials and the emergency response guidance provided in the ERG.4

This report examines (1) what emergency response information is carried 

on trains by selected railroads that transport hazardous materials and 

how responders use it, and (2) how the supplemental emergency 

response information carried on trains of these railroads compares to the 

information in the ERG.

To address both of our objectives, we reviewed relevant literature, 

including the NTSB report on the Paulsboro, New Jersey, incident,5 the 

 3

Supplemental emergency response information is information on responding to 

emergencies involving the release of hazardous materials that some railroads carry on 

their trains in addition to the ERG. 

4 Pub. L. No. 114-94, § 7303, 129 Stat. 1312, 1596 (2015).

5

National Transportation Safety Board, Conrail Freight Train Derailment with Vinyl 

Chloride Release, Paulsboro, New Jersey, November 30, 2012, NTSB/RAR-14/01 

(Washington, D.C.: July 29, 2014).
Page 3 GAO-17-130 Hazardous Materials Rail Shipments

ERG, PHMSA’s Hazardous Materials Regulations (HMR),6 the 

Association of American Railroads’ (AAR) United States Hazardous 

Materials Instructions for Rail,

7 and a prior GAO report on emergency 

response to rail incidents.8 Additionally, we interviewed officials from 

PHMSA and FRA within DOT and NTSB to understand their roles in 

developing, regulating, and making recommendations regarding 

emergency response information on trains.

To identify what emergency response information is carried on trains by 

selected railroads that transport hazardous materials and how responders 

use it, we interviewed two railroad associations, AAR and the American 

Short Line and Regional Railroad Association (ASLRRA), all seven Class 

I railroads, five Class II railroads, and six Class III railroads.9 ASLRRA 

told us it represents approximately 450 of the about 550 Class II and III 

railroads, of which 300 to 400 transport hazardous materials. We initially 

selected seven Class II and seven Class III railroads that carry hazardous 

materials and are ASLRRA members for interviews, but three did not 

respond to our requests for an interview. We selected these Class II and 

Class III railroads by searching PHMSA’s Office of Hazardous Materials 

Safety Incident Reports Database for rail incidents involving hazardous 

materials in transit during 2015 and cross-referencing the carriers’ names 

with ASLRRA’s member list. The railroads we selected are also 

geographically distributed across the United States. The results of the 

interviews cannot be generalized to the entire population of Class II and 

Class III railroads. As described below, we also reviewed information on 

hazardous materials in selected train documents from some of these 

railroads. We interviewed local emergency responders from Montgomery 

 6

49 C.F.R. pts. 171-180. 

7

Association of American Railroads, United States Hazardous Materials Instructions for 

Rail (June 30, 2015). 

8

GAO, Hazardous Materials Rail Shipments: Emergency Responders Receive Support, 

but DOT Could Improve Oversight of Information Sharing, GAO-17-91 (Washington, D.C.: 

Nov. 17, 2016).

9

Railroads are classified into three classes based primarily on annual operating revenues. 

According to the Surface Transportation Board, as of 2015, Class I railroads are those 

with annual operating revenues of at least $457.9 million, Class II railroads are those with 

annual operating revenues of less than $457.9 million but in excess of $36.6 million, and 

Class III railroads are those with annual operating revenues of $36.6 million or less. 49 

C.F.R. § 1201.1-1. Class II freight railroads typically operate over 350 to 900 miles of track 

and Class III freight railroads typically operate over less than 350 miles of track. Class II 

and III railroads are commonly referred to as regional and short line railroads, 

respectively.
Page 4 GAO-17-130 Hazardous Materials Rail Shipments

County, MD; Westmoreland County, PA; and Culbertson, MT. We 

selected the first based on proximity to the audit team in Washington, 

D.C., and the other two because of their involvement in responding to rail 

incidents involving hazardous materials in 2014 and 2015, respectively. 

Additionally, based on its criteria and resources, CHEMTREC identified 

and we spoke with three of the five largest shippers of hazardous 

materials in the United States.10 We also interviewed other 

stakeholders—including four emergency response associations, two train 

crew unions, and CHEMTREC—to learn their perspective on the 

emergency response information carried on trains and how and when 

emergency responders use the information.

To understand how the supplemental emergency response information 

carried on trains of selected railroads compares to the information in the 

ERG, we analyzed information on a nonprobability sample of hazardous 

materials discussed in the ERG and in selected train documents. We 

asked each of the 18 railroads that we interviewed to provide us with a 

nonprobability sample of their train documents, including the “train 

consist” and any supplemental emergency response information, for 15 

trains carrying at least two different hazardous materials and traveling 

between May 12, 2016, and June 30, 2016.11 Eleven of the 18 railroads 

included the supplemental information in their train documents, and for 

our sample, we selected 72 individual hazardous materials across 70 

unique sets of train documents from 10 (6 Class Is, 2 Class IIs, and 2

Class IIIs) of these 11 railroads.12 We selected hazardous materials that 

fell within either AAR’s list of top 125 most frequently transported by tank 

 10CHEMTREC, a program of the American Chemistry Council, serves as a round-theclock resource for obtaining immediate emergency response information for incidents 

involving hazardous materials. According to CHEMTREC, CHEMTREC is linked to the 

largest network of chemical and hazardous material experts in the world, including 

chemical and response specialists, public emergency services, and private contractors.

11The “train consist” is a term used to describe a document that reflects the current 

position in the train of each rail car containing a hazardous material as required by 49 

C.F.R. § 174.26(a). 

12We used the 2012 ERG, as opposed to the recently released 2016 ERG, because not all 

of the selected railroads had begun using the 2016 version during the time frame that the 

sample was taken. Only 8 train documents provided by one of the six Class I railroads met 

our criteria for selecting hazardous materials to include in our review, which is why there 

are two less unique train documents than hazardous materials. The eleventh railroad—a 

Class III—was not able to provide a sufficient sample of train documents that met our 

criteria. Furthermore, none of the train documents it provided contained hazardous 

materials that met our criteria for selecting hazardous materials to include in our review.
Page 5 GAO-17-130 Hazardous Materials Rail Shipments

cars or top 25 most frequently transported by non-tank cars (e.g., 

intermodal trailers or containers on flat cars) in 2014.13 To make the 

comparisons, we first determined which parts of the ERG and the 

supplemental emergency response information in the train documents 

contained information associated with seven requirements for emergency 

response information outlined in the HMR.14 We then examined the 

relevant information associated with each hazardous material in the 

sample and determined where there were similarities and dissimilarities, 

as well as any conflicting information. Furthermore, AAR provided us 

access to its Hazardous Materials Emergency Response Database, 

which is the source for all of the supplemental emergency information in 

the selected train documents, and we compared the supplemental 

emergency response information in the train documents to the database 

to identify any discrepancies. We determined that the supplemental 

emergency response information associated with the sample of 

hazardous materials in the train documents from the 10 railroads we 

reviewed was reliable for the purposes of our report and objectives 

because all of the information came from the AAR Hazardous Materials

Emergency Response Database. The results of our analysis are not 

generalizable to all train documents or all hazardous materials in the ERG

or AAR’s Hazardous Materials Emergency Response Database. For 

further details on our scope and methodology, see appendix I.

We conducted this performance audit from March 2016 to December 

2016 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

According to AAR, hazardous materials comprise about 8 percent of 

commodities shipped by rail in North America—about 2.35 million out of 

 13AAR, Bureau of Explosives, Annual Report of Hazardous Materials Transported by Rail 

2014, BOE 14-1 (Washington, D.C.: July 2015). 

1449 C.F.R. § 172.602(a).

Background
Page 6 GAO-17-130 Hazardous Materials Rail Shipments

29.4 million annual carloads shipped in 2015.15 According to the most 

recent Bureau of Transportation Statistics data available (2012), railroads 

ship about 4 percent of the hazardous materials in the United States by 

tonnage, but railroad shipments account for about 28 percent of distance 

traveled by hazardous materials. The freight railroad industry is 

dominated by the seven Class I railroads, which transport the majority of 

freight—including hazardous materials—in freight containers, portable 

tanks, and other types of rail cars, including tank cars that travel across a 

network of 140,000 miles of track. In addition, numerous Class II and

hundreds of Class III railroads have essential roles in moving freight, 

typically linking rural communities to the larger railroad network.16 Often 

providing “first mile” and “last mile” movements, these smaller railroads, 

taken together, operate on 50,000 miles of track or nearly 40 percent of 

the national railroad network and handle in origination or destination one 

of every four cars moving on the national system.

PHMSA, through its Office of Hazardous Materials Safety, regulates 

shippers and railroads transporting hazardous materials by rail and other 

modes. One way PHMSA fulfills this mission is through the promulgation 

of the HMR for the safe transport of hazardous materials. These 

regulations pertain to the classifying, handling, and packaging of 

shipments of hazardous materials, including rail shipments, and include 

seven requirements that emergency response information must include 

for each hazardous material being shipped.17 These are:

1. The basic description and technical name of the hazardous material.

2. Immediate hazards to health.

3. Risks of fire or explosion.

4. Immediate precautions to be taken in the event of an accident.

 15There are 9 classes of hazardous materials, including Class 3 flammable liquids and 

combustible liquids (49 C.F.R. §173.120), such as petroleum crude oil and ethanol. The 

other classes are: explosives (Class 1)(49 C.F.R. § 173.50); gases (Class 2)(49 C.F.R. § 

173.115); flammable solid, spontaneously combustible, and dangerous when wet (Class 

4)(49 C.F.R. § 173.124); oxidizer and organic peroxide (Class 5)(49 C.F.R. §§ 173.127 

and 173.128); poisonous materials (Class 6)(49 C.F.R. § 173.132); radioactive (Class 

7)(49 C.F.R. § 173.403); corrosive (Class 8)(49 C.F.R. § 173.136); and miscellaneous 

(Class 9)(49 C.F.R. § 173.140). 

16Class I railroads collectively accounted for more than 90 percent of annual railroadfreight revenues in 2012. 

1749 C.F.R. § 172.602(a).
Page 7 GAO-17-130 Hazardous Materials Rail Shipments

5. Immediate methods for handling fires.

6. Initial methods for handling spills or leaks in the absence of fire.

7. Preliminary first aid measures.

The HMR also require railroads to have a document, often referred to as 

the train consist, that identifies basic information about the position in the 

train of each rail car containing hazardous materials.18 The consist also 

typically includes information on the train’s contents, including basic 

descriptions of the hazardous materials transported, and their

destinations, and may include supplemental emergency response 

information, such as details on how to respond to releases of specific 

hazardous materials.

FRA provides regulatory oversight for passenger and freight rail, issuing 

and enforcing safety regulations through its Office of Railroad Safety.19

FRA enforces the HMR and its own regulations through inspections and 

audits by FRA officials, including about 400 federal safety inspectors and 

state partners in some states. For example, according to DOT officials, 

FRA conducts inspections to ensure that railroads carry the required 

emergency response information mentioned above as well as an 

emergency response telephone number in train documentation and 

conduct and keep records of required general-awareness and functionspecific hazardous material training for train crews.

When a rail accident occurs, local emergency responders—police, 

emergency medical technicians, and firefighters—and railroad train crews 

are typically first on the scene of, and often provide the initial response to, 

a rail accident involving hazardous materials.20 For example, local and 

sometimes regional officials may be responsible for advising the public on 

taking shelter-in-place actions or conducting evacuations of affected 

populations.21 In addition, assuming the crews are not affected by an 

 1849 C.F.R. § 174.26(a). 

1949 U.S.C. § 20101.

20According to the National Fire Protection Association, in 2014, 69 percent of the 1.1 

million U.S. firefighters nationwide were volunteers, and communities of 25,000 in 

population or less were more likely to have predominantly volunteer firefighters. NFPA, 

U.S. Fire Department Profile – 2014, January 2016.

21The National Incident Management System provides a common standard for overall 

incident management, including emergency response to rail incidents. It was established 

by the Department of Homeland Security in 2004 to improve coordination and cooperation 

between public and private entities in a variety of incident management activities. 
Page 8 GAO-17-130 Hazardous Materials Rail Shipments

accident, railroad train crews are expected to provide local emergency 

responders with information about the position, type, and quantity of 

hazardous materials on the train as well as written emergency-response 

and contact information for the specific commodities (see fig. 1). The 

HMR also requires railroads to provide immediate notice of certain 

hazardous materials accidents to the National Response Center.22

Figure 1: Initial Response to a Rail Accident Involving Hazardous Materials

 2249 C.F.R. § 171.15.The National Response Center is the sole federal point of contact for 

reporting oil and chemical spills and serves as the communications and operations center 

for the National Response Team, which is led by the Environmental Protection Agency.

The National Response Center is continuously manned by the U.S. Coast Guard to 

provide a single point of contact for receiving and disseminating information in the event of 

a pollution incident. 
Page 9 GAO-17-130 Hazardous Materials Rail Shipments

The ERG, published every 4 years by PHMSA, is a 400-page document 

that contains emergency response information for thousands of 

hazardous materials and for all modes of transportation. It is intended to 

help first responders identify the characteristics of the hazardous 

materials involved in an accident through a table of markings, labels, and 

placards, specific risks associated with the hazardous materials how first 

responders can protect themselves, and procedures for containing the 

accident as quickly and safely as possible.23 The ERG is organized into 

four color-coded sections to help users navigate the document. For 

example, the orange section of the ERG divides hazardous materials into 

63 categories—such as flammable liquids-toxic, flammable gases, and 

oxidizers —with an individual guide for each that provides information on 

types of potential hazards each category poses, including health, fire, or 

explosion hazards.24 The green section provides specific information,

such as initial isolation and protective action distances for small or large 

spills occurring during the day or night, for hazardous materials that are 

considered to be a toxic inhalation hazard (see fig. 2).25

 23A placard is a notice or sign for public display that is used in rail transportation to identify 

hazardous materials on rail cars.

24According to federal regulations, an oxidizer is a material that may, generally by yielding 

oxygen, cause or enhance the combustion of other materials. 49 C.F.R. § 173.127(a). 

25An initial isolation and protective action distance suggests a distance useful to protect 

people from vapors resulting from spills involving hazardous materials that are considered 

toxic by inhalation. According to the ERG, the initial isolation zone defines an area 

surrounding the incident in which persons may be exposed to dangerous and lifethreatening concentrations of material. The protective action zone defines an area 

downwind from the incident in which persons may become incapacitated and unable to

take protective action and/or incur serious or irreversible health effects. A toxic inhalation 

hazard is a term used to describe gases and volatile liquids that are toxic when inhaled.
Page 10 GAO-17-130 Hazardous Materials Rail Shipments

Figure 2: Sample of Sections of the Department of Transportation’s Emergency Response Guidebook

To assist railroads in complying with the HMR, AAR, with the input of 

railroads, develops and makes available to all subscribing railroads the 

United States Hazardous Materials Instructions for Rail, which provides 

general guidelines to the train crew on handling hazardous material 

shipments or incidents safely and efficiently and in accordance with local, 

state, and federal regulations. For example, this document provides 

information on required emergency response information, how the train 

crew and emergency responders are to interact, and what to do when a 
Page 11 GAO-17-130 Hazardous Materials Rail Shipments

fire or vapor cloud is visible. This document also recommends that train 

crews carry the ERG. 

Selected railroads typically carry two sources of emergency response 

information—the train documents and the ERG—to meet the emergency 

response information requirements in federal regulations. Our review of 

selected train documents determined that they always contained the 

position and content of rail cars and the basic descriptions of hazardous 

materials on board the train. In addition, our analysis determined that the 

train documents sometimes included supplemental emergency response 

information. Fifteen of the 18 railroads we spoke with told us that they use 

AAR’s United States Hazardous Materials Instructions for Rail as their 

guidance for meeting train documentation requirements, including 

emergency response information.26 According to the train crews’ unions, 

the ERG and the train documents are kept in the locomotive of the train 

by the train crew, usually a conductor and an engineer. According to FRA 

and PHMSA officials, the ERG’s use is not required by regulation, but is 

viewed by the rail industry as a national standard for emergency response 

information requirements.27 All railroads that we interviewed told us that 

 26The other three railroads use guidance that they say is consistent with the United States 

Hazardous Materials Instructions for Rail. For example, one railroad uses a different 

hazardous material handling rules document developed by a private consulting company 

that was based on AAR’s United States Hazardous Materials Instructions for Rail.

27According to PHMSA, the ERG is the commonly used national guide for meeting the 

requirement for carrying hazardous materials emergency response information under 49 

C.F.R. § 172.602. However, it is important to note that although a shipper must have 

emergency response information, there is flexibility to utilize whatever option a shipper 

chooses to satisfy this requirement, which could be the ERG.

Selected Railroads 

Carry the ERG and 

Train Documents; 

Responders Use This 

Information and 

Additional Sources to 

Determine How to 

Take Action

All Selected Railroads Told 

Us They Carry the ERG, 

While Some Also Carry 

Supplemental Information
Page 12 GAO-17-130 Hazardous Materials Rail Shipments

the ERG is carried aboard its trains as a source of emergency response 

information.

For shipments of hazardous materials, the HMR requires the train crew to 

carry documents with specific information about the hazardous materials 

on board.28 Our review of selected train documents showed that the 

selected railroads included this information in their train documents. 

Additionally, most of the selected railroads included the information in 

their train consist, which identifies the position in the train of each rail car 

and includes other information about the rail car, such as its contents and 

destination. This information includes a basic description of each 

hazardous material being transported on that train, including the 

identification number and proper shipping name, as well as an emergency 

response telephone number, which is provided by the shipper of the 

regulated hazardous material (see fig. 3).29 This telephone number is 

required to be located on documentation carried by the train crew on the 

shipping documents for transportation of the material.30 This basic 

description of the hazardous material the train is transporting meets the 

first of seven emergency-response information requirements in the HMR.

 2849 C.F.R. § 172.202.

29The identification number is a four digit number assigned to hazardous materials to help 

identify the hazardous material during emergency response. 

3049 C.F.R. § 172.604.
Page 13 GAO-17-130 Hazardous Materials Rail Shipments

Figure 3: Information Found in Reviewed Train Documents Regarding the Position and Content of Rail Cars and Emergency 

Response for Specific Hazardous Materials

Our review revealed that some railroads also include supplemental 

emergency response information for each hazardous material on the train 

at the end of the train consist or in a separate document. According to 

AAR, it provides this information to some railroads from its Hazardous 

Materials Emergency Response Database, which AAR develops and 

maintains. Six of the 7 Class I railroads and 5 of the 11 selected Class II 
Page 14 GAO-17-130 Hazardous Materials Rail Shipments

and III railroads included this supplemental information in their trains’

documents.31 Our analysis showed that the amount and content of the 

supplemental emergency response information varied depending on the 

number and type of hazardous materials being transported on a train. For 

each hazardous material on the train, the information can include 5 to 10 

paragraphs, covering 1 to 2 pages of paper. Supplemental emergency 

response information may include information on how to handle fires; 

precautions to be taken in the event of an accident; first aid responses; or 

how to handle air, water, or land spills for that particular hazardous 

material (rather than groups of hazardous materials as with the ERG).

AAR told us the railroads carry this information because, prior to the 

development of the ERG, it was the only source of emergency response 

information carried on trains. However, as discussed later, AAR plans to 

discontinue the use of this database because, among other reasons, new 

sources of information, along with the ERG, have become available to 

emergency responders that contain this type of information.

According to the four emergency response associations we spoke to, 

when responding to a rail accident involving hazardous materials, 

emergency responders primarily rely on information from the train 

documents and the ERG during the first 30 minutes. These associations 

and two local responders we spoke to told us that responders will want to 

immediately learn what hazardous materials are on the train and their 

exact location. There are a couple of ways a responder might begin to 

identify what is on the train. According to all selected responders, if the 

train crew is located quickly, responders would use the train documents to 

identify and locate the hazardous materials on the train. If the train crew is 

incapacitated or cannot be found right away, responders could use 

placards, labels, or markings on the train to identify the hazardous 

materials, according to one emergency response association. According 

to four emergency response associations, responders then may consult 

the ERG to gather more information about the hazardous materials. 

PHMSA, the four emergency response associations, and one local 

responder told us that the ERG is the go-to source for first responders 

during the first 30 minutes or initial phase of an accident. In addition, two 

selected responders told us that the train documents are the best source 

 31The remaining Class I railroad told us that it only carries the ERG along with the basic 

description of the hazardous materials in the train because (1) it prefers to use one source 

for consistency and (2) some of the supplemental emergency response information and 

information in the ERG is repetitive.

According to Emergency 

Response Stakeholders, 

Emergency Responders 

Primarily Use the Train 

Documents and the ERG

in the First 30 Minutes of a 

Rail Incident before 

Obtaining More Specific 

Emergency Response 

Information
Page 15 GAO-17-130 Hazardous Materials Rail Shipments

for the most updated list of the hazardous materials on the train and their 

locations.

According to officials from two emergency response associations, 

emergency response should be thought of in terms of an accident 

timeline. According to these officials, the goal of emergency responders is 

to obtain more specific and detailed information as time goes on, beyond 

the first 30 minutes. During the management of an accident, emergency 

responders move from having unknowns to knowns. According to four 

emergency response associations and two local responders we 

interviewed, as the incident timeline matures, a responder should be 

seeking more comprehensive sources of information on the hazardous 

materials involved in the incident (see fig. 4). One emergency response 

association told us that a responder might consult CHEMTREC, the 

Wireless Information System for Emergency Responders (WISER) 

application, the National Institute for Occupational Safety and Health 

(NIOSH) Pocket Guide to Chemical Hazards, or hotlines for the 

hazardous materials shippers themselves to obtain more specific 

information on chemical properties or tactical information.32 Below is an 

example of a sequence of actions a responder might take in the event of 

a hazardous materials accident, according to our analysis and interviews:

• A responder must first identify the hazardous material involved and its 

location. This could occur using the train documents from the train 

crew if they are located quickly, or if the train crew is incapacitated or 

cannot be found right away, using placards, labels, or markings on the 

train.

• Next, the responder determines initial response actions. Using the 

ERG, the responder might locate the material in the ERG and 

determine which of the 63 guides (orange section) applies. These 

guides provide the basic hazardous material information that a 

responder might want to know immediately, such as evacuation 

distances, risks of fire or explosions, potential health hazards, or 

 32WISER is a system designed to assist emergency responders in hazardous material 

incidents. Developed by the National Library of Medicine, WISER provides a wide range of 

information on hazardous substances, including substance identification support, physical 

characteristics, human health information, and containment and suppression guidance. 

The NIOSH Pocket Guide to Chemical Hazards, published by the National Institute for

Occupational Safety and Health, is a source of general industrial hygiene information for 

workers, employers, and occupational health professionals. The pocket guide presents 

key information and data for 677 chemicals or substance groupings that are found in the 

work environment.
Page 16 GAO-17-130 Hazardous Materials Rail Shipments

protective clothing to wear. If the hazardous material is a toxic 

inhalation hazard, the ERG would direct a responder to its green 

section to gather additional information on isolation and protective 

action distances for small and large spills during the day or night.

• After locating the train crew and the train documents, a responder 

might also consult the supplemental emergency-response information 

in the train’s documents for specifics about the hazardous materials 

involved in the accident. The new AskRail app, developed by AAR 

with data from all the Class I railroads, is another tool that provides 

first responders immediate access to information about the hazardous 

materials on the train. It provides access to real-time train consist 

information and corresponds directly to the emergency response 

information in the ERG associated with each hazardous material on 

the train.

• Later, after the material has been identified and initial response 

actions have been taken, a responder could consult previously 

mentioned sources such as WISER or CHEMTREC about the 

reactivity of the chemical, suggested environmental response 

measures, or suggested first aid measures for that particular 

hazardous material rather than a group of hazardous materials.
Page 17 GAO-17-130 Hazardous Materials Rail Shipments

Figure 4. Timeline of When Specific Emergency Response Information Is Used in a Rail Accident

The interaction between the train crew and emergency responders after a 

rail accident is important because it is the train crew who must provide 

train documents to the responders that lets them know the rail car order, 

the contents of the rail cars, and emergency response information for any 

hazardous materials that the train is transporting. The United States 

Hazardous Materials Instructions for Rail provides guidelines for how this 

interaction between the train crew and responders is to occur. Each 

railroad may modify parts of the United States Hazardous Materials 

Instructions for Rail to reflect their individual policies. Our analysis of the 

instructions provided by selected Class I, II, and III railroads found that 

they had generally consistent guidance on train crew cooperation with 

emergency responders. In each of the instructions that we reviewed, the 
Page 18 GAO-17-130 Hazardous Materials Rail Shipments

train crew is expected to immediately share any requested information 

from the train documents with emergency response personnel. In 

addition, the train crews are instructed to help emergency response 

personnel identify the rail cars and commodities involved, using train 

documents or observation from a safe distance. Five of the seven Class I 

railroads added information to their hazardous materials instructions on 

the process for sharing information with emergency responders. As an 

example, the guidance of one Class I railroad says, “If an extra copy is 

not available, share (DO NOT SURRENDER) the copy you have with the 

emergency response personnel.” One Class II railroad asks its 

employees to note the time, along with the name and title of the person 

provided with the (emergency response) information.

Training received by emergency responders informs the emergency 

response actions taken following a rail hazardous materials accident.33

For example, according to one emergency response association we 

interviewed, emergency responders with basic training, called awareness 

level training, receive training on the ERG, how to read train documents, 

and the other sources of emergency response information that provide 

more specific information on hazardous materials. On the other hand, 

according to one emergency response association and one local 

responder, responders with more advanced training may consult other 

sources of information even in the first 30 minutes of a response. For 

example, a hazardous materials technician for a local responder in 

Montgomery County, MD, told us that he does not use the ERG, but 

instead relies on the NIOSH pocket guide in the first 30 minutes of an 

incident because it provides more precise information than the ERG.

Training for emergency responders may be provided by emergency 

response associations, railroads, or state and local emergency 

 33There are federal requirements that firefighters or other responders receive hazardous 

materials emergency response training, and when such training is provided, federal 

statutes regarding health and safety require that it must be based on training standards 

set by a recognized standard-setting organization, such as the National Fire Protection 

Association. Occupational Safety and Health Act of 1970, Pub. L. No. 91-596, 84 Stat. 

1590 (1970). 40 U. S. C. § 311 and 29 C. F. R. § 1910.120(q) . These standards detail the 

specific knowledge that trainees must have to be considered competent to provide varying 

levels of response to a hazardous materials incident.
Page 19 GAO-17-130 Hazardous Materials Rail Shipments

management agencies, among others.34 According to PHMSA, PHMSA 

also conducts outreach to emergency responders to train them on the 

ERG, including any changes to the ERG if a new version is forthcoming. 

For example, PHMSA officials visited 46 firehouses in fiscal year 2016—

including visits in Olympia, WA, Houston, TX, and Greenville, SC— to 

provide training on the ERG. PHMSA also developed a new online 

training program in April 2016 that introduces emergency responders to 

the hazardous materials regulations and that may also be used to meet 

the requirements for awareness level training, or as the basis for 

developing more advanced training programs.

The content in the ERG and the supplemental emergency response 

information in the train documents we reviewed was generally similar, 

largely aligning with the seven categories of required emergency 

response information for hazardous materials shipments set forth in the 

HMR (see table 1).35 We used the seven requirements in the code of 

federal regulations as a baseline by which to compare the ERG and 

supplemental emergency response information. The specific content was 

 34GAO, Hazardous Materials Rail Shipments: Emergency Responders Receive Support, 

but DOT Could Improve Oversight of Information Sharing, GAO-17-91 (Washington, D.C.: 

Nov. 17, 2016). We found that most local emergency planners we contacted reported that 

rail hazardous-materials training was useful for helping their emergency responders 

prepare for and respond to rail hazardous materials incidents. However, the emergency 

planners also reported that various obstacles impede responders’ participation in training 

activities, such as dedicating time for training, taking unpaid time off of work, and being 

able to get off from their regular duties.

3549 C.F.R. § 172.602(a).

Supplemental 

Emergency 

Response Information 

on Reviewed Train 

Documents Was 

Generally Similar to 

ERG Information

While Generally Similar, 

the Reviewed Information 

in Places Provided 

Different Levels of 

Specificity and Types of 

Information
Page 20 GAO-17-130 Hazardous Materials Rail Shipments

the same in certain instances. For example, both sources recommended 

that, in response to an incident involving propane, responders move 

victims to fresh air and give them artificial respiration if they are not 

breathing. The existence of identical content was, in part, because the 

ERG was one of the sources for the information in the AAR Hazardous 

Materials Emergency Response Database, which, as discussed earlier, 

was the source of the supplemental emergency response information in 

the train documents we reviewed. While the general content and certain 

information in the ERG and the supplemental emergency response 

information we reviewed was similar, the ERG mostly provided 

emergency response information for groups of hazardous materials 

based on their general hazards, while the supplemental emergency 

response information was specific to each hazardous material onboard 

the train (see table 1).
Page 21 GAO-17-130 Hazardous Materials Rail Shipments

Table 1: Comparison of General Content of the Emergency Response Guidebook (ERG) and Supplemental Emergency 

Response Information in Selected Train Documents

Emergency Response 

Information Requirementsa ERG Supplemental Emergency Response Information in Selected Train Documents

The basic description and 

technical name of the 

hazardous material

Lists the proper shipping name and 

universal identification number for all 

hazardous materials.

Lists the proper shipping name, universal identification 

number, and hazard class for each hazardous material 

onboard.

b

Immediate hazards to health Identifies potential health hazards for 

groups of hazardous materials.

Describes each hazardous material onboard;

description may or may not include, among other 

things, health hazards.

Risks of fire or explosion Identifies potential fire or explosion hazards 

for groups of hazardous materials.

Describes each hazardous material onboard;

description may or may not include, among other 

things, fire or explosion risks.

Immediate precautions to be 

taken in the event of an 

accident or incident

Recommends precautions following 

incidents involving groups of hazardous 

materials, including:

• general public safety actions,

• protective clothing to wear when 

responding to an incident, and

• evacuation distances.

Identifies initial isolation and protective 

action distances for individual hazardous 

materials considered toxic by inhalation.

Recommends precautions following incidents involving 

each hazardous material onboard; precautions may or 

may not include:

• general personnel-protection actions,

• protective equipment materials that are safe to 

wear when responding to an incident, and

• evacuation distances.

Immediate methods for 

handling fire

Recommends emergency response actions 

for groups of hazardous materials in 

incidents involving a fire.

Recommends emergency response actions for each 

hazardous material onboard for incidents in which the 

material is on fire or involved in a fire.

Initial methods for handling 

spills or leaks in the absence 

of fire

Recommends emergency response actions 

for groups of hazardous materials in 

incidents involving a spill or leak.

• Recommends emergency response actions for 

each hazardous material onboard for incidents in 

which the material is not on fire or not involved in a 

fire.

• May recommend environmental considerations for 

each hazardous material onboard for land, water, 

and/or air spills involving the material.

Preliminary first aid measures Recommends first aid responses for groups 

of hazardous materials.

Recommends first aid responses for each hazardous 

material onboard.

Source: GAO analysis of Code of Federal Regulations, ERG and supplemental emergency response information data. | GAO-17-130

a

49 C.F.R. § 172.602(a).

b

The train documents we reviewed of one railroad did not include some of this information in its 

supplemental emergency-response information.
Page 22 GAO-17-130 Hazardous Materials Rail Shipments

The supplemental emergency response information that we reviewed was 

intended to augment the ERG and provided more specificity in certain 

areas.

• For example, for an incident involving chlorine, the supplemental 

emergency response information we reviewed recommended digging 

a pit, pond, lagoon, or holding area to contain the spill, while the ERG 

generally recommended preventing entry of the spill into waterways, 

sewers, basements, or confined areas, but did not offer a specific 

means by which to do so.

• Additionally, for an incident involving sodium hydroxide solution—

which is commonly present in commercial drain and oven cleaners—

the supplemental emergency response information we reviewed 

recommended the use of specific materials for protective clothing, 

such as butyl rubber and neoprene, while the ERG generally 

recommended wearing protective clothing recommended by the 

manufacturer of the hazardous material.

• The supplemental emergency response information we reviewed also 

provided information that went beyond what is required by federal 

regulations and included in the ERG, such as physical characteristics 

of the hazardous material, uses, water solubility, and environmental 

hazards.

However, in one area, the ERG often provided more detail than the 

supplemental emergency response information we reviewed. The ERG 

provided specific initial isolation and evacuation distances for incidents 

involving groups of hazardous materials, while the supplemental 

information offered no distance recommendations or deferred to the ERG 

in most of the train documents we reviewed. For example, for a large spill 

of gasoline, the ERG recommended an initial downwind evacuation of at 

least 300 meters, while the supplemental emergency response 

information we reviewed said to consult the ERG for all evacuation 

distances.

The ERG and the supplemental emergency response information we 

reviewed also at times differed on the type of information that was given 

for certain emergency response recommendations. For example, for 

handling spills or leaks, the ERG often provided recommendations 

according to the size of the incident, such as small or large spills, while 

the supplemental information we reviewed often provided 

recommendations according to the environment, such as air, land, or 

water spills.
Page 23 GAO-17-130 Hazardous Materials Rail Shipments

In reviewing the ERG and train documents in our nonprobability sample 

belonging to our selected Class I, II, and III railroads, we found 

inconsistent information for 8 of the 72 hazardous materials we selected.

• Two inconsistencies involved differences in a first aid response 

recommendation regarding the amount of time to flush skin or eyes 

with running water in case of contact with the substance. The 

differences were 5 minutes in one instance and 10 minutes in another.

• Six inconsistencies involved discrepancies between the 

recommended evacuation distances in the two sources.

o For four of the six hazardous materials with evacuation distance 

inconsistencies, the supplemental emergency response 

information recommended an evacuation distance of a half mile 

for an incident involving fire, while the ERG recommended one 

mile. These four hazardous materials were all labeled as United 

Nations identification number 1075, which represents multiple 

liquefied petroleum gases.

o For another of the hazardous materials, sodium chlorate, the ERG 

recommended an evacuation distance of a half mile, while the 

supplemental emergency response information recommended the 

same distance, but only if the resulting fire was uncontrollable.

o For the final hazardous material, ammonium nitrate, the ERG

recommended an evacuation distance of a half mile in all 

directions for an incident involving fire, while the supplemental 

emergency response information recommended one mile for an 

uncontrollable fire.

The NTSB report on the Paulsboro, New Jersey, incident highlighted 

inconsistencies between recommended evacuation distances in the 

supplemental emergency response information in the train documents 

and the ERG for two of the hazardous materials on the train, chlorine and 

vinyl chloride.36 This finding led to NTSB’s recommendation that AAR 

update its database to ensure that its guidance is consistent with and at 

least as protective as the ERG.

37 In response to NTSB’s 

 36Unlike the ERG, the vinyl chloride supplementary emergency response information 

appended to the train consist did not specify an initial evacuation radius for a “release 

without fire.” Additionally, its guidance for evacuations during a fire was only half the 

evacuation distance (0.5 miles) recommended by the ERG (1 mile).

37National Transportation Safety Board, Conrail Freight Train Derailment with Vinyl 

Chloride Release, Paulsboro, New Jersey, November 30, 2012, NTSB/RAR-14/01 

(Washington, D.C.: July 29, 2014). 

We Found Several 

Inconsistencies in 

Prescribed Evacuation 

Distances, but Recent 

AAR Plans Would 

Eliminate Potential for 

Similar Discrepancies
Page 24 GAO-17-130 Hazardous Materials Rail Shipments

recommendation, AAR replaced all existing evacuation distance 

statements in its Hazardous Materials Emergency Response Database, 

effective August 1, 2014, with a statement to consult the ERG for 

protective action considerations, including initial isolation or evacuation 

distances and shelter-in-place recommendations. Additionally, AAR made 

other changes to the database effective December 1, 2014. NTSB found 

AAR’s response actions to be unacceptable because AAR did not revise 

emergency response information that was less conservative than the 

equivalent precautions contained in the ERG.

As described above, our analysis showed that some railroads did not 

capture these changes, including the new evacuation distance 

recommendations, and continued to provide specific evacuation distances 

for hazardous materials in their train documents that were inconsistent 

with the ERG. AAR is planning a change that is intended to remove the 

potential for such discrepancies. Specifically, according to AAR, AAR 

hazardous materials committee members—which consist of 

representatives of the 7 Class I railroads—unanimously voted in August 

2016 to discontinue the support, production, and distribution of the AAR 

Hazardous Materials Emergency Response Database. According to AAR, 

although the Class II and III railroads did not vote on the change, the 

database will no longer be supported, produced, or distributed, making it 

effective for all railroads. Since emergency responders have access to 

the ERG and other resources with more specific information than the 

ERG—such as WISER, the NIOSH pocket guide, safety data sheets, 

CHEMTREC, and the shipper—the supplemental emergency response 

information has become obsolete, according to one AAR official.

We provided a draft of this report to DOT and NTSB for their review and 

comment. DOT provided a technical comment about hazardous material 

training requirements, which we incorporated. NTSB provided a technical 

comment about AAR’s response to their recommendation to revise 

discrepancies between emergency response information found in AAR’s 

database and the ERG, which we incorporated.

Agency Comments
Page 25 GAO-17-130 Hazardous Materials Rail Shipments

We will send copies of this report to the appropriate congressional 

committees and to the Secretary of Transportation and the Chairman of 

the National Transportation Safety Board. In addition, the report will be 

available at no charge on the GAO website at http://gao.gov.

If you or your staff have any questions about this report, please contact 

Susan Fleming at (202) 512-2834 or flemings@gao.gov. Contact points 

for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. Major contributors to this report are 

listed in appendix II.

Susan Fleming

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-17-130 Hazardous Materials Rail Shipments

Our objectives were to examine: (1) what emergency response 

information is carried on trains by selected railroads that transport 

hazardous materials and how responders use it and (2) how the 

supplemental emergency response information1 carried on trains of these 

railroads compares to the information in the Emergency Response 

Guidebook (ERG).

To inform both of our objectives, we reviewed relevant literature, including 

the National Transportation Safety Board (NTSB) report on the 

Paulsboro, New Jersey incident,2 the ERG, and a prior GAO report on 

emergency response to rail incidents.3 We reviewed the Association of 

American Railroads’ (AAR) United States Hazardous Materials 

Instructions for Rail, to understand industry guidelines on how to meet 

federal hazardous material regulations, including the emergency 

response information to be carried on trains and how railroad personnel 

are expected to interact with first responders.4 We also examined relevant 

sections of the Hazardous Materials Regulations (HMR) to determine 

requirements for railroads related to emergency response information 

carried on trains transporting hazardous materials.5 Additionally, we 

interviewed officials from the Pipeline and Hazardous Materials Safety 

Administration (PHMSA) and the Federal Railroad Administration (FRA) 

within the Department of Transportation (DOT) and NTSB to understand 

their roles in developing, regulating, and making recommendations 

regarding emergency response information on trains.

To identify what emergency response information is carried on trains by 

selected railroads that transport hazardous materials and how responders 

use it, we interviewed two railroad associations, AAR and the American 

 1

Supplemental emergency response information is information on responding to 

emergencies involving the release of hazardous materials that some railroads carry on 

their trains in addition to the ERG.

2

National Transportation Safety Board, Conrail Freight Train Derailment with Vinyl 

Chloride Release, Paulsboro, New Jersey, November 30, 2012, NTSB/RAR-14/01 

(Washington, D.C.: July 29, 2014).

3

GAO, Hazardous Materials Rail Shipments: Emergency Responders Receive Support, 

but DOT Could Improve Oversight of Information Sharing, GAO-17-91 (Washington, D.C.: 

Nov. 17, 2016).

4

Association of American Railroads, United States Hazardous Materials Instructions for 

Rail (June 30, 2015). 

5

49 C.F.R. pts. 171-180. 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-17-130 Hazardous Materials Rail Shipments

Short Line and Regional Railroad Association (ASLRRA), and all seven 

Class I railroads.6 ASLRRA told us it represents approximately 450 of the 

about 550 Class II and III railroads, of which 300 to 400 transport 

hazardous materials. We selected seven Class II and seven Class III 

railroads that carry hazardous materials and are ASLRRA members, 

using PHMSA’s Office of Hazardous Materials Safety Incident Reports 

Database and a member list provided by ASLRRA. We searched 

PHMSA’s database for railroads that experienced an incident in transit 

during 2015, which resulted in a list of railroads that carry hazardous 

materials that we could cross-reference with the ASLRRA member list. 

The railroads we selected are also geographically distributed across the 

United States. Of those fourteen selected Class II and III railroads, we 

spoke with representatives of five Class II and six Class III railroads. The 

other three did not respond to our requests for an interview. The results of 

the interviews cannot be generalized to the entire population of Class II 

and Class III railroads. As described below, we also reviewed information 

on hazardous materials in selected train documents from some of these 

railroads. Fifteen (7 Class Is, 4 Class IIs, and 4 Class IIIs) of the 18 

railroads we interviewed provided us with at least one set of train 

documents. We selected one set of train documents from each of those 

railroads to determine how the basic description and technical name of 

hazardous materials the train is transporting and the emergency response 

telephone number are displayed. The results of the analysis are not 

generalizable to all of the train documents of the selected railroads or all 

railroads. We also spoke with CHEMTREC regarding its role in providing 

information to first responders.7 Additionally, we interviewed three of the 

five largest shippers of hazardous materials in the United States—ExxonMobil, Dow Chemical Company, and BASF—to determine what 

emergency response information they provide to railroads and emergency 

 6

Railroads are classified into three classes based primarily on annual operating revenues. 

According to the Surface Transportation Board, as of 2015, Class I railroads are those 

with annual operating revenues of at least $457.9 million, Class II railroads are those with 

annual operating revenues of less than $457.9 million but in excess of $36.6 million, and 

Class III railroads are those with annual operating revenues of $36.6 million or less. 49 

C.F.R. § 1201.1-1. Class II freight railroads typically operate over 350 to 900 miles of track 

and Class III freight railroads typically operate over less than 350 miles of track.

7

CHEMTREC, a program of the American Chemistry Council, serves as a round-the-clock 

resource for obtaining immediate emergency response information for incidents involving 

hazardous materials. According to CHEMTREC, CHEMTREC is linked to the largest 

network of chemical and hazardous material experts in the world, including chemical and 

response specialists, public emergency services, and private contractors. 
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-17-130 Hazardous Materials Rail Shipments

responders. CHEMTREC identified and provided the contact information 

for the three shippers based on their criteria and resources.

We also interviewed local emergency responders in Montgomery County, 

MD, Westmoreland County, PA, and Culbertson, MT to learn their 

perspective on the emergency response information carried on trains and 

how and when emergency responders use the information. We chose the 

first organization because of its proximity to the audit team in Washington, 

D.C. and the other two because of their involvement in responding to rail 

incidents involving hazardous materials in 2014 and 2015, respectively. 

We determined their involvement by searching PHMSA’s Incident Reports 

Database for serious rail incidents in transit over the last 5 years that

resulted in a hazardous materials’ release and talking to the first 

responders associated with the city or county listed in the database. We 

also interviewed representatives from four emergency response 

associations—three national associations representing local emergency 

responders, including the International Association of Fire Chiefs, 

International Association of Firefighters, and the National Volunteer Fire 

Council, as well as the National Fire Protection Association, which 

develops, among other things, standards for emergency response to 

hazardous materials incidents. Additionally, we spoke with two train crew 

unions—the Brotherhood of Locomotive Engineers and Trainmen and the 

International Association of Sheet Metal, Air, Rail and Transportation 

Workers—to understand the role of the train crews in emergency 

response and how they interact with emergency responders following a 

rail incident.

To understand how the supplemental emergency-response information 

carried on trains of selected railroads compares to the information in the 

ERG, we analyzed information on a nonprobability sample of hazardous 

materials discussed in the ERG and in train documents. We used the 

2012 ERG, as opposed to the recently released 2016 ERG, because not 

all of selected railroads had begun using the 2016 version during the 

timeframe that the sample was taken. We asked each of the 18 railroads 

that we interviewed to provide us with a nonprobability sample of their 

train documents, including the “train consist”8 and any supplemental 

emergency response information, for 15 trains carrying at least two 

different hazardous materials and traveling between May 12, 2016, and 

 8

The “train consist” is a term used to describe a document that reflects the current position 

in the train of each rail car containing a hazardous material as required by 49 C.F.R. § 

174.26(a). 
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-17-130 Hazardous Materials Rail Shipments

June 30, 2016. Eleven of the 18 railroads (6 Class Is, 2 Class IIs, and 3

Class IIIs) provided train documents that contained supplemental 

emergency response information. From those train documents, we 

selected a sample of 72 unique hazardous materials that were in either 

the AAR’s top 125 hazardous commodities list as measured by loaded 

tank car originations or top 25 hazardous commodities list as measured 

by loaded non-tank-car originations (e.g., intermodal trailers or containers 

on flat cars) in 2014.9 The sample represented 70 unique sets of train 

documents from 10 of the 11 railroads that carried the supplemental 

emergency response information. The sample included 10 hazardous 

materials in 10 sets of train documents from five of the six Class I 

railroads, 10 in 8 sets of train documents from the sixth Class I railroad,10

5 in 5 sets of train documents from both Class II railroads, and 1 in 1 set 

of train documents from two of the three Class III railroads.11

To make the comparisons, we first determined which parts of the ERG 

and the supplemental emergency response information in the train 

documents contained information that is associated with the seven 

requirements for emergency response information outlined in the HMR.12

We then examined each hazardous material in the sample by comparing 

the relevant sections in each source and determining where there are 

similarities and differences, as well as any conflicting information. The 

results of our analysis are not generalizable to all train documents or all 

hazardous materials in the ERG. Furthermore, AAR provided us access 

to its Hazardous Materials Emergency Response Database. We 

 9

Association of American Railroads, Bureau of Explosives, Annual Report of Hazardous 

Materials Transported by Rail 2014, BOE 14-1 (Washington, D.C.: July 2015). The first list 

includes the top 125 hazardous commodities shipped in railroad tank cars in the U.S., 

Canada, and Mexico in 2014, ranked in descending order by number of originations. 

These 125 commodities account for approximately 95 percent of shipments of hazardous 

commodities in railroad tank cars. The second list includes the top 25 hazardous 

commodities shipped in railcars other than tank cars in the U.S., Canada and Mexico in 

2014, ranked in descending order by number of originations. These 25 commodities 

account for approximately 71 percent of the rail shipments of hazardous commodities not 

transported in tank cars.

10None of the other train documents provided by this railroad met our criteria for selecting 

hazardous materials to include in our review.

11The third Class III railroad was not able to provide a sufficient sample of train documents 

that met our criteria. Furthermore, none of the train documents it provided contained 

hazardous materials that met our criteria for selecting hazardous materials to include in 

our review. 

1249 C.F.R. § 172.602(a).
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-17-130 Hazardous Materials Rail Shipments

determined that the supplemental emergency response information 

associated with the sample of hazardous materials in the reviewed train 

documents from the 10 railroads was reliable for the purposes of our 

report and objectives because all of the information came from the AAR 

Hazardous Materials Emergency Response Database. We determined 

that the database was the appropriate source of the information in the 

reviewed train documents through interviews with officials from each of 

the 10 railroads. We compared the supplemental emergency response 

information on the sample of hazardous materials in the reviewed train 

documents to the information on those hazardous materials in the source 

database for the time period reflected by the dates of the train documents 

(May 12, 2016, to June 30, 2016). The results of our analysis are not 

generalizable to all train documents or all hazardous materials in the AAR 

Hazardous Materials Emergency Response Database. We also 

interviewed supply chain software providers ShipXpress and GE 

Transportation to learn how the Class II and Class III railroads receive 

access to the AAR Hazardous Materials Emergency Response Database.

We conducted this performance audit from March 2016 through

December 2016 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 31 GAO-17-130 Hazardous Materials Rail Shipments

Susan Fleming, (202) 512-2834 or Flemings@gao.gov

In addition to the individual name above, Nancy Lueke (Assistant 

Director), Kieran McCarthy (Analyst in Charge), Moira Lenox, Garrett 

Riba, Josh Ormond, William Egar, Dave Hooper, Delwen Jones, Reuben 

Montes de Oca, and Kelly Rubin made key contributions to this report.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contacts

Staff 

Acknowledgments

(100721)
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