West Building, W35-322

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

of Transportation Washington, D.C. 20590

Federal Railroad Administration

FRA-AIP 200611-01

REVIEW DATE: January 1, 2025

1. GRANTEE:

American Industrial Transport, Inc.

100 Clark Street

St. Charles, MO 63301

2. PURPOSE:

a. This approval authorizes the use of an Alternative 

Inspection and Test Program (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 AIP only 

considered the hazards and risks associated with the 

transportation in commerce.

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

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

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

AMERICAN RAILCAR INDUSTRIES approved November 28, 2006 and 

subsequent letter from AMERICAN INDUSTRIAL TRANSPORT, INC.

dated August 13, 2020 submitted in accordance with 49 CFR

180.509(l).
Continuation of FRA-AIP 200611-01 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 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 – AMERICAN INDUSTRIAL TRANSPORT, 

INC. must 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 

Nondestructive Testing (NDT) method at the time of 

manufacture. This does not provide any relief from the 

requirements of Association of American Railroads (AAR) 

Manual of Standards and Recommended Practices (MSRP)

Section C-III Appendix W. For tank cars lacking these 

measurements, AMERICAN INDUSTRIAL TRANSPORT, INC. must 

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 

AIP. The sample size must be determined by following 

recognized industry sampling standards.

c. DESIGN LEVEL OF RELIABILITY AND SAFETY – AMERICAN 

INDUSTRIAL TRANSPORT, INC. must 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 reliability 

and safety or fail within its operational life or prior to 

the next required inspection. AMERICAN INDUSTRIAL
Continuation of FRA-AIP 200611-01 Page 3 of 6

TRANSPORT, INC. must maintain all documentation used to 

make such determination at its principal place of business 

and make the data available to the Federal Railroad 

Administration (FRA) or an authorized representative of the 

Department of Transportation upon request.

d. SENSITIVITY AND RELIABILITY – AMERICAN INDUSTRIAL

TRANSPORT, INC. must develop and execute a sensitivity and 

reliability study to determine the level of reliability, 

sensitivity and minimum detectable flaw size for the NDT

methods and techniques used to maintain the design level of 

reliability and safety.

e. CONTROL – AMERICAN INDUSTRIAL TRANSPORT, INC. must 

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 AIP 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 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 200611”. Additionally, 
Continuation of FRA-AIP 200611-01 Page 4 of 6

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 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. AMERICAN INDUSTRIAL TRANSPORT, INC. must 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 AIP.

b. AMERICAN INDUSTRIAL TRANSPORT, INC. must 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 
Continuation of FRA-AIP 200611-01 Page 5 of 6

the bottom longitudinal centerline on any Tank Car subject 

to this AIP.

c. AMERICAN INDUSTRIAL TRANSPORT, INC. must 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 must report this listing to FRA every 

5 years or upon request.

d. AMERICAN INDUSTRIAL TRANSPORT, INC. shall report 

CONTROL results to FRA every 5 years or upon request.

9. LIMITATIONS:

a. If a tank car operating under this approval is 

transferred from AMERICAN INDUSTRIAL TRANSPORT, INC. 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:

FRA may rescind this approval for failure to comply with

its terms.

Issued in Washington, D.C.:

______________________________________ November 9, 2020

Karl Alexy

Associate Administrator for Railroad Safety

Chief Safety Officer
Continuation of FRA-AIP 200611-01 Page 6 of 6

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

11/2006 Original approval

A 10/2020 Updated format; added review terms; added control 

conditions; added limitations; updated company 

name as requested