West Building, W35-322

U.S. Department 1200 New Jersey Avenue S.E.

of Transportation Washington, D.C. 20590

Federal Railroad Administration

FRA-AIP 200204-01

REVIEW DATE: January 1, 2026

1. GRANTEE:

DOW Chemical Company

2211 H.H. Dow Way

Midland, MI 48674

2. PURPOSE AND LIMITATION:

a. This approval authorizes the use of an Alternative 

Inspection and Test Program as allowed by 49 CFR 180.509(l) 

Alternative inspection and test procedures. This letter 

provides no relief from the Hazardous Materials Regulations 

(HMR) other than as specifically stated herein. The most 

recent revision supersedes all previous revisions.

b. The damage tolerance analysis or service reliability 

assessment performed in the development of this Alternative 

Inspection and Test Program only considered the hazards and 

risks associated with the transportation in commerce.

c. The approval to use an Alternative Inspection and Test 

Program is non-transferrable.

3. REGULATIONS AFFECTED: 49 CFR § 180.509(e)(1)(iii). 

4. BASIS: This approval is based on the application of DOW 

CHEMICAL COMPANY dated April 16, 2002 submitted in 

accordance with § 180.509(l).
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5. INSPECTION AND TEST PROCEDURES:

a. Definitions

1. Service Reliability Assessment – the process, 

using in-service data, to determine the time a tank 

car or component will continue to function as designed 

under specified conditions.

2. Tank Car Owner - the person to whom a rail car's 

reporting marks are assigned, as listed in the 

Universal Machine Language Equipment Register (UMLER).

3. Damage-Tolerance Analysis – Determination of the 

probable locations and modes of damage due to fatigue, 

corrosion or accidental damage. The analysis must 

establish a period of time/load cycles during which it 

is demonstrated that widespread fatigue or corrosion 

damage will not occur in the tank car structure.

b. BENCHMARK TESTING – DOW CHEMICAL COMPANY shall develop 

a sampling plan to measure the adequacy of tank shell butt 

welds within 60.96 cm (2 feet) of the bottom longitudinal 

centerline with an approved Non-Destructive Testing Method

at the time of manufacture. This does not provide any 

relief from the requirements of AAR MSRP Section C-III 

Appendix W. For tank cars lacking these measurements, DOW 

CHEMICAL COMPANY shall perform Inspection and Test of tank 

shell butt welds within 60.96 cm (2 feet) of the bottom 

longitudinal centerline at the time of next qualification 

but not to exceed the maximum allowable interval given in 

49 CFR 180.509(c)(3) or the maximum allowable interval 

permitted by an applicable Approved Alternative Inspection

Program. The sample size must be determined by following 

recognized industry sampling standards.

c. DESIGN LEVEL OF RELIABILITY AND SAFETY – DOW CHEMICAL 

COMPANY shall maintain an analysis (e.g., finite element 

analysis, damage-tolerance analysis, or service reliability 

assessment) that the structure will not develop defects 

that reduce the design level of safety and reliability or 

fail within its operational life or prior to the next 

required inspection. DOW CHEMICAL COMPANY shall maintain 

all documentation used to make such determination at its 

principal place of business and make the data available to 
Continuation of FRA-AIP 200204 Page 3 of 7

FRA or an authorized representative of the Department upon 

request.

d. SENSITIVITY AND RELIABILITY – DOW CHEMICAL COMPANY

shall develop and execute a sensitivity and reliability

(POD) study to determine the level of reliability, 

sensitivity and minimum detectable flaw size for the NonDestructive Testing Methods and Techniques used to maintain 

the design level of reliability and safety.

e. CONTROL – DOW CHEMICAL COMPANY shall perform Inspection 

and Test of tank shell butt welds within 60.96 cm (2 feet) of 

the bottom longitudinal centerline on a representative 

subgroup of the fleet covered by this Alternative Inspection 

Program approval based on the identified crack development 

and growth rate, utilization, and other factors to ensure 

continued applicability of this program. All tank cars in 

this sample must have benchmark testing as defined in section 

(b) above. These reports must be made available to FRA or a 

designated representative upon request. The sample size must 

be determined by following recognized industry sampling 

standards.

6. SPECIAL PROVISIONS:

a. A person who is not a holder of this approval who 

receives a package covered by this alternative inspection 

and test approval may reoffer it for transportation 

provided no modification or change is made to the package 

or its contents and it is reoffered for transportation in 

conformance with this approval and the HMR.

b. A current copy of this approval shall be maintained at 

each facility where the package is maintained and/or

repaired.

c. Marking of each tank car is required and must meet the 

marking and labeling requirements of 49 CFR Part 172, 

Subpart D. The car must be identified by a stencil or 

decal placed above the tank specification number. The 

stencil must have at least 1 1/2-in high (38.1 mm) letters

and numbers and display “FRA-AIP 200204”. Additionally, 

the car must have the initial qualification year 

(QUALIFIED) and the next qualification year (DUE). This 

interval must be developed from the Service Reliability 
Continuation of FRA-AIP 200204 Page 4 of 7

Assessment. Marking must occur at time of next shopping by

a tank car facility, not to exceed the maximum allowable 

interval given in 49 CFR 180.509(c)(3) or the maximum 

allowable interval permitted by an applicable Approved 

Alternative Inspection Program.

7. COMPLIANCE: Failure by a person to comply with any of the 

following may result in suspension or revocation of this 

approval and penalties prescribed by the Federal hazardous 

materials transportation law, 49 U.S.C. 5101 et seq:

a. The grantee must comply with all terms and conditions 

prescribed in this approval and the Hazardous Materials 

Regulations, 49 CFR 171-180.

b. Each "Hazmat employee", as defined in § 171.8, who 

performs a function subject to this approval must receive 

training on the requirements and conditions of this 

Alternative Inspection and Test Program in addition to the 

training required by §§ 172.700 through 172.704.

c. No person may use or apply this Alternative Inspection 

and Test Program, including display of its number, when 

this approval has lapsed or is otherwise no longer in 

effect.

8. REPORTING REQUIREMENTS:

a. DOW CHEMICAL COMPANY shall notify the Associate 

Administrator for Railroad Safety, Chief Safety Officer, in 

writing no later than 30 days after any incident involving 

tank shell butt welds within 60.96 cm (2 feet) of the 

bottom longitudinal centerline of a Tank Car conducted 

under terms of this Alternative Inspection Program 

Approval.

b. DOW CHEMICAL COMPANY shall report in writing to the 

Associate Administrator for Railroad Safety, Chief Safety 

Officer no later than 30 days after notification of 

occurrence, instances of corrosion damage or tank failure 

not considered in the damage-tolerance analysis or service 

reliability assessment that adversely affects tank shell 

butt welds within 60.96 cm (2 feet) of the bottom 

longitudinal centerline on any Tank Car subject to this 

Alternative Inspection Program Approval.
Continuation of FRA-AIP 200204 Page 5 of 7

c. DOW CHEMICAL COMPANY shall maintain a listing of tank 

cars by reporting mark and number operating under this 

approval to include the status of the above required 

marking and shall report this listing to the Federal 

Railroad Administration every 5 years or upon request.

d. DOW CHEMICAL COMPANY shall report CONTROL results to 

the Federal Railroad Administration every 5 years or upon 

request.

9. LIMITATIONS:

a. If a tank car operating under this approval is 

transferred from DOW CHEMICAL COMPANY to another Tank Car 

Owner then the tank car will no longer be subject to the 

relief granted under this approval and all the above 

required stenciling must be removed. The qualification due 

date must be changed to reflect the new Tank Car Owner’s 

Qualification Interval in accordance with the new Tank Car 

Owner’s qualification and maintenance program.

10. CANCELLATION

The FRA may rescind this approval for failure to comply 

with its terms.

Issued in Washington, D.C.:

______________________________________ March 9, 2021

Karl Alexy

Associate Administrator for Railroad Safety

Chief Safety Officer
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Address all inquiries to: Randy M Keltz Jr., Manager, Tank Car 

Safety Programs, Federal Railroad Administration, U.S. 

Department of Transportation, West Building, 1200 New Jersey

Avenue, Southeast, Washington, D.C. 20590.

Photo reproductions and legible reductions of this approval are

permitted. Any alteration of this approval is prohibited.

REVISION HISTORY

REV DATE DESCRIPTION

04/2002 Original approval

A 01/2021 Updated format; added review terms; added control 

conditions; added limitations;