Cargo Tank Trucks:

Improved Incident Data and Regulatory Analysis Would Better Inform Decisions about Safety Risks

GAO-13-721: Published: Sep 11, 2013. Publicly Released: Sep 11, 2013.

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What GAO Found

The Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration's (PHMSA) incident data cannot be used to reliably identify risks from incidents involving collisions with and spills from tank trucks' bottom lines ("wetlines") because the incidents are not specifically identified in PHMSA's database and the data contain inaccuracies. PHMSA requires carriers to report hazardous material incidents, but the reporting form does not specifically capture wetline incidents. PHMSA officials identify wetline incidents through a resource-intensive process of reviewing carrier-reported incident narratives and other information. However, GAO found that the narratives do not always clearly indicate whether an incident is wetline related and that information about the consequences of incidents, including fatalities, is not always accurate. PHMSA has made efforts to improve its data, such as adding quality checks, but this has not affected how wetline incidents are reported, and inaccuracies remain.

One technology to purge liquid from wetlines exists, but use of this system is limited, and industry and safety stakeholders expressed concerns about it, such as concerns about the safety of retrofitting existing trucks with the device and its cost. Although other options have been proposed to address wetline risks, none has been pursued, and there are concerns about their safety and feasibility as well. For example, wetlines could be drained at loading terminals, but this creates issues over storing the drained fuel and whether it could be resold.

PHMSA analyzed the costs and benefits of its proposed 2011 rule to prohibit transportation of flammable liquids in unprotected wetlines, but did not account for uncertainties in its analytical assumptions and limitations in the underlying incident data. For example, PHMSA's analysis overstated the number of fatalities the proposed rule would prevent when considering actual past incidents. Furthermore, PHMSA based its cost analysis on the assumption that carriers would install a certain type of wetline purging system, but its limited adoption makes that cost uncertain. Federal guidance recommends that agencies account for uncertainty in regulatory analysis, such as limitations in PHMSA's data and uncertainty in its assumptions. Without having done so, PHMSA's analysis may not accurately represent the costs and benefits of its proposed rule.

Why GAO Did This Study

Cargo tank trucks deliver gasoline and other flammable liquids daily for consumer use. Trucks are loaded and unloaded through external bottom lines that, after loading, may contain up to 50 gallons of liquid and are known as "wetlines." Concerns have been raised about the safety of wetlines, since a collision may rupture them, releasing flammable liquid and possibly causing fatalities and property damage. PHMSA is responsible for regulating the safe transportation of hazardous materials and has proposed rules prohibiting the transport of flammable liquids in wetlines.

In 2012, The Moving Ahead for Progress in the 21st Century Act required GAO to examine this issue. This report discusses (1) the extent that PHMSA's data reliably identify wetline safety risks, (2) options for addressing wetline safety risks, and (3) how well PHMSA has assessed the costs and benefits of addressing these risks through regulation. GAO analyzed PHMSA's wetline incident data for 1999 to 2011, reviewed PHMSA's regulatory cost-benefit analyses, and interviewed agency officials and industry and safety stakeholders.

What GAO Recommends

DOT should improve its wetline incident data by requiring carriers to specifically report wetline incidents and by improving its information on incident consequences. DOT should also address uncertainty in the assumptions and data underlying its regulatory cost-benefit analysis. DOT did not agree or disagree with the recommendations, but provided technical comments.

For more information, contact Susan A. Fleming at (202) 512-2834 or flemings@gao.gov.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: Cargo tank trucks that deliver gasoline and other flammable liquids are loaded and unloaded through external "wetlines" on the bottom of the tank that, after loading, may contain up to 50 gallons of liquid. Concerns have been raised about the safety of wetlines, since a collision may rupture them, releasing flammable liquid and possibly causing fatalities and property damage. The Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) is responsible for regulating the safe transportation of hazardous materials and collects data on incidents involving hazardous materials. In September 2013, GAO found that PHMSA's incident data cannot be used to reliably identify risks from incidents involving collisions with and spills from wetlines because the incidents are not specifically identified in PHMSA's database and the data contain inaccuracies. For example, PHMSA requires carriers to report hazardous material incidents, but the reporting form does not specifically capture wetline incidents. PHMSA officials identify wetline incidents through a resource-intensive process of reviewing carrier-reported incident narratives and other information. However, GAO found that the narratives do not always clearly indicate whether an incident is wetline-related and that information about the consequences of incidents, including fatalities, is not always accurate. Therefore, GAO recommended that PHMSA revise its incident reporting to better capture wetline incidents and their consequences. In 2015 and 2016, GAO confirmed that PHMSA has taken action to address this recommendation. Specifically, PHMSA submitted a Hazardous Materials Transportation Incidents Data Assessment and Improvement Plan to Congress, including an evaluation of the collection requirements for the incident reporting form, which set forth the agency's plan for improving data. PHMSA also established a dashboard in the agency's web-based reporting system to assist Data Operations technical staff in identifying potential wetlines incidents. PHMSA also created an Incident Investigation System to better understand the contributing causes of incident failures. The system involves validating all the fields on an incident reporting form submitted to PHMSA and collecting additional data from sources such as police/fire accident reports, coroners' reports, company backgrounds, and past enforcement actions. PHMSA officials also stated that training sessions have been held with Data Operations staff and Field Operations staff on validation of all the fields in the incident reporting form. As a result, PHMSA has more detailed and reliable information to identify incidents involving wetlines, and to better assess the potential risk from such incidents.

    Recommendation: To improve the reliability of data used to identify wetline incidents, the Secretary of Transportation should direct the Administrator of PHMSA to revise incident reporting to better capture wetline incidents and their consequences, such as by requiring specific reporting of wetline incidents by modifying the reporting form to include a specific indicator of such incidents, and adjusting the incident reporting form to indicate whether there are minimal costs versus no costs when costs are below the $500 reporting threshold.

    Agency Affected: Department of Transportation

  2. Status: Open

    Comments: PHMSA established a dashboard in the agency's web-based reporting system to identify potential wetlines incidents. PHMSA officials also improved coordination within DOT by creating a system that sends potential wetlines reports directly to modal partners and internal subject matter experts. Furthermore, PHMSA officials stated that training sessions have been held with Data Operations staff and Field Operations staff on validation of all the fields in the incident reporting form. However, PHMSA still needs to complete several additional efforts to fulfill this recommendation, most notably the creation of specific wetlines validation codes for incident reporting.

    Recommendation: To improve the reliability of data used to identify wetline incidents, the Secretary of Transportation should direct the Administrator of PHMSA to address limitations with the accuracy and completeness of information used to assess the impact of wetline incidents, such as by specifying circumstances when PHMSA should seek missing cause and cost information, and potentially using sources other than the carrier to acquire information (such as investigations by local law enforcement or other federal agencies), particularly for the most severe incidents for which having accurate incident information is critical to oversight.

    Agency Affected: Department of Transportation

  3. Status: Closed - Implemented

    Comments: Cargo tank trucks that deliver gasoline and other flammable liquids are loaded and unloaded through external "wetlines" on the bottom of the tank that, after loading, may contain up to 50 gallons of liquid. Concerns have been raised about the safety of wetlines, since a collision may rupture them, releasing flammable liquid and possibly causing fatalities and property damage. The Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) is responsible for regulating the safe transportation of hazardous materials and, in 2011, proposed a rule prohibiting the transport of flammable liquids in unprotected wetlines. In September 2013, GAO reported that, while PHMSA had analyzed the costs and benefits of its proposed rule, the agency did not account for uncertainties in its analytical assumptions and limitations in the underlying incident data. For example, PHMSA's analysis overstated the number of fatalities the proposed rule would prevent when considering actual past incidents. PHMSA also based its cost analysis on the assumption that carriers would install a certain type of wetline purging system, but limited experience with that technology made that cost uncertain. By not accounting for these uncertainties, as federal guidance recommends, GAO found that PHMSA's analysis may not have accurately represented the costs and benefits of its proposed rule. Therefore, GAO recommended that PHMSA strengthen the regulatory assessment of the proposed wetline rule's costs and benefits to better address the uncertainty of underlying factors. In response, PHMSA revised its economic analysis to consider additional underlying factors. Specifically, in a document issued in December 2015, PHMSA stated that it examined the regulatory assessment for the proposed rule, taking into account the GAO findings as well as industry comments to help make a determination on whether to withdraw the rulemaking. In its revised analysis, PHMSA considered additional economic factors to calculate estimated benefits and costs and found that estimated benefits were less than estimated costs in most scenarios PHSMA considered. PHMSA concluded that, although a safety hazard exists, prohibiting the transportation of flammable liquids in wetlines is unlikely to be cost beneficial. However, before PHMSA acted in response to its updated analysis, the "Fixing America's Surface Transportation Act'' passed in December, 2015, included a mandate for PHMSA to withdraw its proposed wetlines rule; the agency subsequently withdrew the rule on December 30, 2015. Before the act's passage, PHMSA's reassessment of the proposed rule better addressed the uncertainty in its analysis and provided assurance that the legislative action to withdraw the rule was in line with the cost-benefit analysis, which showed that the rule's estimated costs exceeded estimated benefits.

    Recommendation: To strengthen the agency's rulemaking analysis, the Secretary of Transportation should direct the Administrator of PHMSA to strengthen the regulatory assessment of the proposed wetline rule's costs and benefits to better address the uncertainty of underlying factors. Such action could include incorporating more real-world information about purging systems or, if considered, other wetline solutions, and conducting additional sensitivity analyses for areas of uncertainty that are not addressed by improved data collection.

    Agency Affected: Department of Transportation

 

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