West Building

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

of Transportation Washington, D.C. 20590

Federal Railroad Administration

FRA-AIP 200409-B

REVIEW DATE: January 1, 2026

1. GRANTEE:

GATX Corporation

233 S. Wacker Drive

Chicago, Illinois 60606-7147

2. PURPOSE AND LIMITATION:

a. This approval authorizes the use of an alternative 

inspection and test procedure (AIP) 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 AAIP only 

considered the hazards and risks associated with the 

transportation in commerce.

c. This approval to use an AIP is non-transferrable.

3. REGULATIONS AFFECTED: 49 CFR §§ 180.509(d), 180.509(e), 

180.509(f), 180.509(h), 180.509(k). 

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

Corporation dated September 2, 2004 submitted in accordance 

with § 180.509(l). This letter supersedes the previous 

approvals dated July 8, 2005 and September 13, 2006 and any 

modifications to those approvals.
Continuation of FRA-AIP 200409-B Page 2 of 6

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 

manufacturing, 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: All new GATX tank cars added to 

this program must, at the time of manufacture, have 

External and Internal Visual Inspection, Ultrasonic 

Thickness Testing (UTT) measurements, Structural Integrity 

Filet Weld inspections, and Safety Systems inspections. For 

the existing fleet of tank cars lacking these measurements, 

GATX must develop a sampling plan and take External and 

Internal Visual Inspection, UTT measurements, Structural 

Integrity Filet Weld inspections, and Safety Systems 

inspections. The sample size must be determined by 

following recognized industry sampling standards.

c. DESIGN LEVEL OF RELIABILITY AND SAFETY: GATX shall 

ensure that any visually detected tank car external and 

internal damage, tank thickness reductions, structural 

integrity flaws, safety system defects and service equipment 

defects do not decrease its design level of reliability and 

safety.

d. SENSITIVITY and RELIABILITY: For tank cars operating 

under this AIP, GATX must develop and execute a sensitivity 

and reliability (POD) study to determine the level of 

reliability, sensitivity and minimum detectable flaw size 

for each nondestructive method used to qualify each element 
Continuation of FRA-AIP 200409-B Page 3 of 6

of the qualification to maintain the design level of 

reliability and safety.

e. CONTROL: GATX must perform External and Internal 

Visual Inspection, UTT measurements, Structural Integrity 

Filet Weld inspections, and Safety Systems inspections on a 

representative sample of the fleet covered by this AIP 

approval. The frequency must be based on the identified 

corrosion rate, utilization, and other factors to maintain 

the design level of reliability and safety and must be made 

available to the Federal Railroad Administration (FRA) or a 

designated representative upon request. The sample size 

must be determined by following recognized industry 

sampling standards.

6. REGULATORY RELIEF:

a. The interval for the initial performance of the 

external and internal visual inspection is extended to 15 

years from the date of construction, with subsequent 

inspections at 10-year intervals.

b. The interval for the initial performance of the 

structural integrity inspection of filet welds is extended 

to 15 years from the date of construction, with subsequent 

inspections at 10-year intervals.

c. The interval for the initial performance of the tank 

car thickness testing inspection is extended to 15 years 

from the date of construction, with subsequent inspections 

at 10-year intervals.

d. The interval for the initial performance of the safety 

systems inspection including thermal protection systems, 

insulation systems, discontinuity protection and head 

puncture resistance systems is extended to 15 years from 

the date of construction, with subsequent inspections at 

10-year intervals.

e. The interval for the initial performance of the 

service equipment inspection for GATX owned service 

equipment is extended to 15 years from the date of 

construction, with subsequent inspections at 10-year 

intervals.
Continuation of FRA-AIP 200409-B Page 4 of 6

7. SPECIAL PROVISIONS:

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

receives a package covered by this AIP 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 AIP approval and 

the HMR.

b. A current copy of this AIP approval must 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 200401”. 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 

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 AIP.

d. If a tank car operating under this approval is removed 

from the AIP or it exceeds the original qualification 

intervals, all AIP markings must be removed.

8. 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 HMR, 49 CFR Parts 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 AIP in 

addition to the training required by 49 CFR Part 172, 

Subpart H.
Continuation of FRA-AIP 200409-B Page 5 of 6

c. No person may use or apply this AIP, including display 

of its number, when this approval has lapsed or is 

otherwise no longer in effect.

9. REPORTING REQUIREMENTS:

a. GATX must notify the Associate Administrator for 

Railroad Safety, Chief Safety Officer, in writing no later 

than 30 days after notification of any incident involving a 

Tank Car conducted under terms of this AIP.

b. GATX must report instances of corrosion damage or tank 

failure not considered in the damage tolerance analysis or 

service reliability assessment on any car subject to this 

approval to FRA within five days of being notified of such 

occurrence.

c. GATX must maintain a list of tank cars by reporting 

mark and number operating under this approval to include 

the status of the above required marking and will report 

this listing to FRA every 5 years or upon request.

d. GATX must report CONTROL results (see paragraph 5(d) 

above) to FRA every 5 years or upon request.

10. LIMITATIONS:

a. If a tank car operating under this approval is

transferred from GATX 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. If the new due date is in the 

past, the qualification is due immediately.

11. CANCELLATION:

FRA may rescind this approval for failure to comply with 

its terms.
Continuation of FRA-AIP 200409-B Page 6 of 6

Issued in Washington, D.C.:

______________________________________ March 4, 2021

Karl Alexy

Associate Administrator for Railroad Safety

Chief Safety Officer

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

Safety Programs, Federal Railroad Administration, U.S. 

Department of Transportation, randy.keltz@dot.gov.

Photo reproductions and legible reductions of this approval are 

permitted. Any alteration of this approval is prohibited.

REVISION HISTORY

REV DATE DESCRIPTION

2004 Original approval

A 2005 Amended approval to allow all new W1 and W3 cars 

to be added to the approval.

B 03/2021 Updated to new format; added benchmark testing 

requirements; added control requirements; Section 

5(b) changed to clarify maximum interval allowed 

to include other AIPs; this revision incorporates

approval GATX AIP 200507