ISSUE BRIEF 03.20.19 Is There a Correlation between Vapor Pressure and the Severity of Crude Oil Transportation Incidents?

Rachel A. Meidl, LP.D., CHMM, Fellow in Energy and Environment, Center for Energy Studies

actions called for improved standards TRANSPORT OF CRUDE BY RAIL for both new and existing tank cars INCREASING (retrofitting or new design specifications, Although crude oil has been transported such as thermal blankets and top-fittings); 4 by rail for years, there is a noticeable a sampling and testing program; reduced uptick in the Permian Basin and Bakken operating speeds; information sharing to 5 region as companies struggle to build state emergency response commissions; 6 pipeline infrastructure to meet production enhanced braking; and comprehensive oil 7 demands that are further delayed by legal spill response plans. Not long after, then- challenges and public opposition. This President Barack Obama signed the Fixing resurgence could place pressure on the America’s Surface Transportation Act (FAST U.S. Department of Transportation’s (DOT) Act) into law, which instructed DOT to Pipeline and Hazardous Materials Safety institute additional regulatory amendments Administration (PHMSA) to revitalize efforts to tank car design standards and to revise to assess the safe transport of crude oil the tank car phase-out schedule codified in the HHFT rule, prioritizing crude oil and Pipelines are the safest by rail and to specifically consider the means to transport roles of vapor pressure1 and volatility2 in ethanol. Neither the HHFT final rule nor an accident scenario. Past high-profile the FAST Act directly addressed the role of energy, with pipelines accidents have raised concerns for volatility or vapor pressure thresholds of safely delivering PHMSA about the safety of rail transport crude oil transported by rail. over 99.999% of all There were several lines of reasoning of crude oil, including physical and shipments. The efficacy chemical properties; adequacy of transport behind this deliberate oversight. PHMSA did regulations; rail integrity; packaging; and not propose new rules concerning vapor and strong safety conditioning and stabilization practices. pressure, incentives to reduce volatility, record of the pipeline In response to some of these concerns, or other specific requirements related to transportation system vapor pressure in the notice to proposed PHMSA published a final rule that went should be underscored into effect in July 2015, the Enhanced Tank rulemaking of the HHFT. Accordingly, the Car Standards and Operational Controls for agency could not introduce new changes or as a viable and safe High-Hazard Flammable Trains (HHFT),3 an obligations in the final HHFT rule, as doing so means of transport for expansive multibillion-dollar rulemaking would violate the Administrative Procedures crude oil. intended to improve the safe transportation Act by omitting public comment prior to a 8 of large quantities of flammable materials, rule becoming final. Also, in 2014 after many particularly crude oil and ethanol, by rail. years of discussion, the rail and oil industry, The HHFT rule and other congruous agency with PHMSA’s participation, developed the RICE UNIVERSITY’S BAKER INSTITUTE FOR PUBLIC POLICY // ISSUE BRIEF // 03.20.19

first ever recommended practice designed to measurement methods and conditions improve crude oil rail safety through proper utilized by PHMSA, the NDIC, Transport sampling, testing, classification, and loading Canada, and various oil operators to practices. This resulted in an American test for vapor pressure throughout the National Standards Institute recognized 2013-2105 sampling period were not industry standard and American Petroleum consistent. Furthermore, the vapor Institute Recommended Practice 3000, pressure methodology PHMSA employed Classifying and Loading of Crude Oil into Rail is not currently incorporated into the U.S. Tank Cars.9 In addition, the North Dakota regulations, nor are they integrated into Neither the UN Model Industrial Commission (NDIC), a body that Canada’s Transportation of Dangerous Good Regulations, Transport regulates oil and gas drilling and production (TDG) regulations or the United Nations (UN) Canada’s dangerous in North Dakota, issued a conditioning order Model Regulations. The lack of harmonization requiring all oil producers in the state to and recognition by these entities could cause goods regulations, nor significantly reduce the vapor pressure of all enforcement issues as well as significant the U.S. hazardous Bakken crude oil beginning April 1, 2015.10 hazard classification and package selection materials regulations During this time, since a large proportion of discrepancies (e.g., non-pressurized tank car define “vapor pressure” the crude oil shipped on rail was originating versus a pressurized tank car). Nearly every from the Bakken region, PHMSA chose to interested party disagrees with how crude or how it should rely on North Dakota and other oil-producing oil should be sampled and tested (open cup be determined and states to regulate the risk of vapor pressure versus closed cup, pressurized versus non- measured. through the NDIC order. Consequently, on pressurized), what vapor pressure reading is January 18, 2017, two days before President most relevant for crude oil classification and Donald Trump was inaugurated, PHMSA transportation (Reid Vapor Pressure, or RVP, published an Advance Notice of Proposed Reid equivalent, or true vapor pressure),11 and Rulemaking (ANPRM) soliciting input on the conditions of measurement (vapor-to- the volatility of petroleum products and liquid ratio and temperature) that would yield flammable liquids and the consideration reproducible and accurate vapor pressures. of the establishment of a national vapor The general lack of uniformity in methods pressure threshold for these commodities on and quality assurance/quality control any mode of transport. across the industry creates complications when comparing crude oil vapor pressure. Further, how a sample is collected and tested WHY IS VAPOR PRESSURE AN ISSUE? produces wildly disparate results, making all the difference when classifying the materials The concern with high vapor pressure is and selecting the appropriate packaging and that it is indicative of a higher proportion of transport system. organic compounds of low molecular weight Second, although technically vapor such as methane, ethane, or propane, known pressure is a key property in determining as “light ends,” as well as elevated levels of whether a substance meets the definition dissolved gases. There are widely diverging of a liquid or gas, neither the UN Model opinions within DOT and industry regarding: Regulations, Transport Canada’s TDG, nor (1) the role vapor pressure and volatility play the U.S. hazardous materials regulations in a normal transportation incident, (2) if define “vapor pressure” or how it should elevated levels of dissolved gases increase be determined and measured. It is also the volatility of crude oil, and (3) if high important to note that the current U.S. vapor pressure accentuates the severity definition for a flammable gas differs from of consequences of an incident. However, various international regulations, including studies have not conclusively quantified the Transport Canada’s. In the U.S., the regulatory potential hazard associated with higher vapor language for distinguishing between a pressure in crude oil transportation scenarios. flammable gas and flammable liquid is Several issues warrant attention insufficient to manage materials that are a should PHMSA reopen this topic. First, mixture of dissolved flammable gases within the standardized sampling, testing, and a flammable liquid. The crude oil samples 2 IS THERE A CORRELATION BETWEEN VAPOR PRESSURE AND THE SEVERITY OF CRUDE OIL TRANSPORTATION INCIDENTS?

collected by PHMSA, the NDIC, and Transport Canada yielded vapor pressure readings that VAPOR PRESSURE: MISALIGNED would push the classification from what CONDITIONS FOR RULEMAKING would traditionally be a primary hazard class Since 2013, PHMSA has taken a number of flammable liquid to a primary hazard class actions to improve the safe transport of flammable gas. crude oil. Due to a shift in priorities with With this designation, a crude oil that the change in political leadership, the meets the definition of a flammable gas Trump administration tabled the Obama- (with a secondary hazard classification as a era ANPRM on the volatility of petroleum flammable liquid) would theoretically require products. The ANPRM was PHMSA’s reaction a more robust means of containment during to several crude oil incidents and petitions transport, such as a pressurized tank car for for rulemaking, as well as the results of rail or pressurized tank truck for highway As of today, PHMSA crude oil sampling and testing conducted by transportation. However, there is technically PHMSA, Transport Canada, the NDIC, and oil still needs to determine no existing authorized tank or rail car to operators between 2013 to 2015. The data what role, if any, transport dissolved gases in flammable yielded a range of vapor pressure results, liquids since U.S. and international vapor pressure plays some exceeding the limit set by the NDIC. regulations lack a classification scheme for in the severity of a The presumption in the ANPRM was that a mixture of this type. Another new tank car transportation incident, limiting the product’s vapor pressure could specification standard for transporting high reduce the risk of death or damage from fire and how it should be vapor pressure crude oils with dissolved or explosion in an accident or derailment. defined in the construct gases would not sit well with industry, The Trump administration, through which was recently mandated to phase out of the regulatory several executive orders and directives, DOT-111 tank cars in favor of an enhanced framework. altered agency priorities and reformed the non-pressurized tank car, DOT-117, the regulatory agenda to “eliminate regulatory most technically rigorous specifications for burdens”14 that “unnecessarily encumbered carrying crude oil. This change stemmed energy production, constrained economic from the HHFT rulemaking PHMSA finalized growth, and prevented job creation.”15 It in the wake of the tragic Lac-Megantic also mandated that the total incremental crude oil derailment in Canada.12 cost of all new regulations, including Additionally, crude oil shipped from repealed regulations, be no greater Canada’s shale plays contains dissolved than zero.16 These actions considerably hydrogen sulfide, a highly toxic and reprioritized the agency’s agenda, and flammable gas. How this interacts with the rulemaking quickly plummeted to low the classification scheme of high vapor priority on the regulatory schedule. pressure crude oil taxonomy and packaging Besides a reformation of administration is uncertain, as toxic gas transportation priorities that promptly sidelined the requires additional safety specifications. ANPRM, the concern by DOT was the dearth This highlights the limitations of the current of scientific evidence demonstrating that testing methods for hydrogen sulfide in vapor pressure is correlated to safety the vapor phase. Precise quantification of outcomes in accidents. While numerous hydrogen sulfide in crude oil is a critical entities have collected data (including practice for product quality control, as PHMSA, Sandia National Laboratories, the well as worker and transportation safety North Dakota Petroleum Council, Transport purposes. In particular, quantification of Canada, Canadian Crude Quality Technical hydrogen sulfide is critical due to its high Association, and various companies in the toxicity in the gas phase. Exposures as low oil industry), none to date have illustrated as 100 ppm can be fatal.13 Using proper that vapor pressure or volatility increases sampling techniques, temperature, and the consequences or probability of accidents headspace conditions in ranges normally involving trains transporting large quantities encountered during operations or transport of flammable liquids. would certainly provide a better assessment of the true hazard. 3 RICE UNIVERSITY’S BAKER INSTITUTE FOR PUBLIC POLICY // ISSUE BRIEF // 03.20.19

This was also evidenced in the first interregional transport of hazardous phase of Sandia National Laboratories’ materials. The UN recommendations are multiyear crude oil characteristics research negotiated internationally and implemented (commissioned in 2014 by DOT and the into domestic regulations by regulatory U.S. Department of Energy via a FAST bodies in each country, including Mexico’s Act congressional mandate) through Secretariat for Communications and a comprehensive data and literature Transport, Transport Canada, DOT, etc. PHMSA review, which concluded that there is is obligated through international agreements no established relationship between to ensure harmonization with UN standards crude oil properties and the probability regarding the classification and transport of and severity of combustion events in rail hazardous materials. Unilateral deviations car scenarios.17 However, the study is from these standards would affect the multiphase and intended to link key crude continuity of commerce between the U.S., oil properties to behavior in a derailment Canada, and Mexico. scenario. Therefore, completing each Federal law strongly favors the phase of research is necessary to make harmonization of domestic and international informed policy decisions. Since the scope standards, but the law may deviate to of work represents a phased approach promote safety or other overriding public where knowledge gained from completing interests.18 Unilateral or arbitrary changes Equally critical to each task informs the execution of to the U.S. domestic regulations that are deciding whether vapor subsequent tasks, a proposed rulemaking incongruous with the UN Model Regulations pressure plays a role that anticipated inaugurating a unilateral on the Transportation of Dangerous Goods vapor pressure threshold was premature. requirements would severely constrain in accident scenarios Moreover, an incident scenario involving a transborder shipments and create regulatory is determining which derailment, tank car breach, pool fire, and uncertainty for shippers and carriers. As the nationally recognized subsequent tank car breaches presents volume of hazardous materials transported in standardized sampling multiple complex variables with poorly international commerce continues to grow, understood kinetics—the solution is not harmonization is increasingly important. and analysis methods simply a matter of capping the vapor The ANPRM, which contemplates a national are best suited to pressure. Without adequate modeling U.S. vapor pressure threshold, is in direct provide accurate and and experimental verification, it is not contravention to these global priorities. reproducible data to possible to estimate the degree to which characterize crude oil. dissolved flammable gases contribute to the severity of incidents. The third phase SAFEST MODES OF TRANSPORT of this study was recently completed, which included combustion experiments Nearly a million shipments of hazardous and computational modeling to assess materials, such as crude oil, move the effects of individual characteristics of throughout the U.S. each day on various select crude oil on its burn behavior. A draft modes of transport. Pipelines and barges report is currently in peer review and is have accommodated substantial portions scheduled to be published this spring. of the growth in domestic energy products, From an international commerce and they have accomplished this without perspective, harmonization of safety significant new safety issues and within the measures facilitates international trade by framework of their regulatory and safety 19 minimizing the costs and other burdens of assurance systems. Tank barges have a complying with multiple or inconsistent long history of transporting crude oil, ethanol, requirements between countries. The UN and natural gas liquids (NGL) with improved Model Regulations are designed to reduce safety performance as a result of extensive trade barriers, promote global access to emergency preparedness planning and markets, encourage economic development, response training informed by lessons learned and improve safety, compliance, and from catastrophic oil spills more than 30 enforcement capabilities while streamlining years ago. training requirements for multimodal 4 IS THERE A CORRELATION BETWEEN VAPOR PRESSURE AND THE SEVERITY OF CRUDE OIL TRANSPORTATION INCIDENTS?

Crude oil transported via barge condensate, and NGLs. In accordance with expanded rapidly after 2010 as hydraulic the U.S. hazardous materials regulations, fracking activities increased the demand the offeror must consider all hazards when for crude oil transportation inland and on classifying a hazardous material and account intracoastal waterways. Although traffic for whether the crude oil they intend to ship volumes of maritime transport exceed those exhibits hazards beyond that of a flammable of rail due to the large quantities of crude liquid, such as corrosivity, toxicity, etc. To oil transported along the Gulf Coast, the reinforce this requirement, PHMSA proposed safety record of energy liquids movement a new regulation in 2015 requiring a sampling via waterways has been exemplary, with and testing program for shippers of unrefined no reports of ethanol or NGL releases from petroleum-based products, including crude tank barges over the last 10 years and rare oil, for all modes of transport. Shippers reports of crude oil releases.20 are required to consider and document Certainly, different modes of oil the varying characteristics and properties transport pose different risks, but aside of unrefined petroleum-based products. from the maritime transportation system’s However, vapor pressure testing was not commendable track record, pipelines are explicitly noted. the safest means to transport energy, with Should PHMSA move forward with pipelines safely delivering over 99.999% the ANPRM and reinvigorate the vapor Rather than changing 21 of all shipments. However, despite the pressure debate, there are key actions that the physical and efficacy and safety record of pipelines, will improve domestic and international expansion projects such as Keystone XL transport harmonization, reduce compliance chemical properties and Trans Mountain continue to stall due uncertainty, and clarify enforcement of the transported to public opposition and legal hurdles. In strategies. As of today, the agency still materials, preventative geographic regions of the country that lack needs to determine what role, if any, efforts should be sufficient pipeline takeaway capacity and vapor pressure plays in the severity of infrastructure, rail and surface highways are a transportation incident, and how it taken through a the only means to transport the commodity should be defined in the construct of the comprehensive, from the production site to where it can be regulatory framework. This has not yet been systematic investigation refined and ultimately consumed. established by PHMSA, but it is important that examines so that the regulated community and other immediate, underlying, stakeholders have transparent agency IS THERE A WAY FORWARD? direction and consistent requirements. and root causes. Notably, pipeline operators routinely set Proper classification is a critical step in upper limits on RVP levels for crude oil the transportation process for ensuring accepted for transport to a distribution hazardous materials are shipped safely. point as a matter of operational efficiency Determining whether vapor pressure and and standard operating procedures for volatility play a role in transportation safety compliance with the Clean Air Act governing is important for consistency in classification, the emission of volatile organic compounds packaging selection, compliance, and in tanks. PHMSA has suggested that insight enforcement. Unlike manufactured goods on how oil producers comply with the vapor or finished products, organic materials from pressure standards of pipeline operators, oil and gas production represent a unique or how they ship crude oil with RVP levels challenge in regard to classification. Unrefined that exceed pipeline operator limits by rail, petroleum-based products, including crude could yield important information about oil, have variable chemical properties and the significance of setting RVP limits for compositions. Differences in the raw material rail or highway transport. In the pipeline can vary across wellheads and fluctuate industry, however, a variety of factors affect based on time, geographic location, and the degree to which an oil is conditioned method of extraction. Consequently, there are and stabilized for post-production multiple hazardous liquids that are commonly transport in the oil and gas supply chain, shipped from the wellsite, including crude oil, such as engineering, design standards, 5 RICE UNIVERSITY’S BAKER INSTITUTE FOR PUBLIC POLICY // ISSUE BRIEF // 03.20.19

product specifications, market demands, and evaluate a variety of factors, including economics, existing infrastructure, and quantifying safety improvements, if any; government regulations. Apart from the balancing the benefits and costs (especially NDIC vapor pressure standards, establishing in a deregulatory administration with vapor pressure thresholds is not merely a below-zero regulatory budget); and an exercise based exclusively on safety. evaluating the extent to which the enhanced Maintaining product quality from the DOT-117 tank cars mitigate the risk of wellhead to the refinery is essential, so transporting crude oil. any modifications in vapor pressure during Transport Canada debriefed two UN transportation could disrupt and reverberate Committees of Experts22 in December 2015 throughout the supply chain. This is about their sampling and testing findings especially true if downstream operations on crude oils carried by highway and rail for are configured with a separate vapor UN consideration to formally undertake this pressure, as vapor pressure is a function of issue, as it has relevance to all members the engineering and design of the pipeline, where crude oil is extracted, transported, the intended resulting product, and the or handled. Should the UN decide to specification of the downstream consumer. advance this topic, unresolved matters Examining vapor pressure practices between such as discrepancies in the definition of a the pipeline and other transport industries flammable gas, vapor pressure significance, may raise awareness about why and how and the appropriate classification and pipelines set vapor pressure standards, but packaging of crude oil with dissolved gases this information may not be relevant or will have to be reconciled within the current transferrable to rail or highway. domestic U.S. regulatory framework. Equally critical to deciding whether Rather than changing the physical and vapor pressure plays a role in accident chemical properties of the transported scenarios is determining which nationally materials, preventative efforts should recognized standardized sampling and be taken through a comprehensive, analysis methods are best suited to systematic investigation that examines provide accurate and reproducible data to immediate, underlying, and root causes characterize crude oil, with emphasis on such as track integrity and geometry, vapor pressure and light ends content. This equipment deficiencies, and human will improve the ability to preserve original factor contributions. Proper infrastructure sample integrity; prevent contamination maintenance and transportation practices with inert atmospheric gases during are also key to reducing accidents. sampling, handling, and analysis; and Furthermore, there are dozens of actions compare results across industry. As underway since the rollout of the HHFT previously noted, there are currently rule and other FAST Act requirements. For numerous industry standards for sampling instance, PHMSA recently issued a final rule and determining vapor pressure of crude oil to revise requirements for comprehensive and other flammable liquids. oil spill response plans that will improve There is also room for improving the response readiness and mitigate the effects understanding of crude oil vapor pressure of rail incidents involving petroleum oil,23 measurements for characterizing the a requirement that expands upon oil spill volumes and compositions of gases that are response rules already established in both likely to evolve from crude oil in transport the Clean Water Act of 1972 and the Oil spill scenarios. More research is needed to Pollution Act of 1990. This rulemaking, determine if and how these properties relate along with the HHFT final rule and other to fire and explosion hazards. In the event complementary congressionally mandated that a national vapor pressure threshold for actions, is expected to improve the safe the transportation of crude oil and other transport of energy products. petroleum products is established, PHMSA would need to promulgate a rulemaking

6 IS THERE A CORRELATION BETWEEN VAPOR PRESSURE AND THE SEVERITY OF CRUDE OIL TRANSPORTATION INCIDENTS?

2. Volatility is directly related to a CONCLUSION substance’s vapor pressure. At a given PHMSA has long considered numerous temperature, a substance with higher regulatory and nonregulatory actions that vapor pressure vaporizes more readily than would enhance the safety of transporting a substance with a lower vapor pressure. crude oil by rail. With crude-by-rail A substance with a high vapor pressure at shipments increasing and projected normal temperatures is often referred to to continue as pipeline projects face as volatile. opposition and delays, pressure on the 3. HHFTs are continuous blocks of 20 agency to take action lingers from multiple or more tank cars loaded with a flammable petitions for rulemaking, numerous liquid, or 35 or more tank cars loaded with a National Transportation Safety Board flammable liquid dispersed through a train. recommendations associated with such 4. Requirements implemented through petitions, and congressional interest, 49 CFR, section 173.41. Effective July 7, 2015. including several legislative mandates. 5. The information sharing requirement Although PHMSA postponed immediate was adopted into PHMSA’s “Oil Spill Response action on the proposed rulemaking to Plans and Information Sharing for High Hazard consider a vapor pressure cap (DOT’s Flammable Trains” rulemaking, issued in Fall 2018 Unified Agenda denotes “Next February 2019. 84 F.R. 6910. Action Undetermined”),24 domestic and 6. PHMSA rescinded its electronically international interest will likely continue to controlled pneumatic (ECP) braking systems force the agency into action. mandate after updated regulatory impact Appropriate classification is necessary analysis showed that the expected costs of to ensure proper packaging, operational requiring ECP brakes would be significantly controls, and hazard communication, all higher than the expected benefits. of which are imperative to mitigate the 7. PHMSA, “Hazardous Materials: Oil Spill negative effects of a train derailment or Response Plans and Information Sharing for other hazardous materials incident. While High Hazard Flammable Trains (FAST Act),” more research is needed to determine 84 F.R. 6910, February 28, 2019, https:// the correlation of vapor pressure with www.phmsa.dot.gov/sites/phmsa.dot.gov/ the severity of consequences of crude oil files/docs/standards-rulemaking/hazmat/ transportation events, time should be allowed rulemakings/70471/hm-osrp-final-rule-fr- for the existing and unfolding crude oil submission_1.pdf. safety plan to take root. In the meantime, as 8. 80 Fed. Reg. at 26665. industry continues to research and integrate 9. Energy API, ANSI/API Recommended new methods and technologies to manage Practice 3000 (API Global: Washington, D.C., and upgrade the integrity of the nation’s 2014), www.api.org/oil-and-natural-gas/ pipeline network, the efficacy and strong wells-to-consumer/transporting-oil- safety record of the pipeline transportation natural-gas/rail-transportation/api- system should be underscored as a viable and rp-3000. safe means of transport for crude oil. 10. North Dakota Industrial Commission (NDIC) Oil Conditioning Order No. 25417. 11. Vapor pressure, Reid Vapor Pressure, ENDNOTES and true vapor pressure are often used interchangeably with reference to crude oils, 1. Vapor pressure is pressure exerted leading to considerable confusion. by a vapor escaping from a liquid; it is 12. In 2013, 63 loaded tank cars carrying quantified as the tendency of molecules to crude oil from the Bakken region of North enter the gaseous phase. The vapor pressure Dakota derailed and ignited in Lac-Megantic, of a mixture is commonly defined as the Quebec, killing 47 people. The locomotives pressure where the first bubble of vapor is separated from the train and came to rest formed at a given temperature, but there about 1/2 mile east of the derailment. At are other definitions based on standardized least 60 of the 63 derailed DOT-111 tank cars experimental measurements or correlations. 7 RICE UNIVERSITY'S BAKER INSTITUTE FOR PUBLIC POLICY // ISSUE BRIEF // 03.20.19

released about 1.6 million gallons of crude oil. and rail. Although the committee found no 13. See “Hydrogen sulfide,” The National new safety problems have emerged from Institute for Occupational Safety and the increased use of pipelines transporting Health, Centers for Disease Control and larger amounts of domestic oil and gas, Prevention, https://www.cdc.gov/niosh/ substantially more pipeline mileage and npg/npgd0337.html. higher traffic volumes may result in more 14. Executive Order 13777, “Enforcing pipeline releases over time, simply because of the Regulatory Reform Agenda,” February the increase in exposure. The safety impact, 24, 2017, 82 F.R. 12285, https://www. however, is likely to depend on the extent govinfo.gov/content/pkg/FR-2017-03-01/ to which new pipeline technologies, leak pdf/2017-04107.pdf. monitoring systems, and more vigilant and 15. Executive Order 13783, “Promoting capable integrity management programs are Energy Independence and Economic Growth,” effective in protecting the newer pipelines March 28, 2017, https://www.whitehouse. and the older ones that connect to them. gov/presidential-actions/presidential- 22. These were the UN Sub-Committee of executive-order-promoting-energy- Experts on the Transport of Dangerous Goods, independence-economic-growth/. and the UN Committee Sub-Committee of 16. Executive Order 13771, “Reducing Experts on the Globally Harmonized System of Regulation and Controlling Regulatory Costs,” Classification and Labelling of Chemicals. January 20, 2017, https://www.govinfo.gov/ 23. PHMSA, “Hazardous Materials: Oil Spill content/pkg/DCPD-201700084/pdf/DCPD- Response Plans and Information Sharing for 201700084.pdf. High Hazard Flammable Trains (FAST Act).” 17. Tay Aulich and Chad Wocken, “DOE 24. See “Hazardous Materials: Crude Oil Characterization Research Study – Vapor Pressure of Unrefined Petroleum See more issue briefs at: Project Update,” (PowerPoint presentation, Products and Class 3 Materials,” Office of www.bakerinstitute.org/issue-briefs Crude Oil Quality Association Meeting, Information and Regulatory Affairs, U.S. This publication was written by a Minneapolis, MN, June 11, 2015), https:// Office of Management and Budget, researcher (or researchers) who www.osti.gov/servlets/purl/1256267; https://www.reginfo.gov/public/do/ participated in a Baker Institute project. David Lord and Anay Luketa. DOE Crude Oil eAgendaViewRule?pubId=201810&RIN= Wherever feasible, this research is Characterization Research Study – Project 2137-AF24. reviewed by outside experts before it is released. However, the views expressed Update, June 1, 2015, https://prod-ng. herein are those of the individual sandia.gov/techlib-noauth/access-control. author(s), and do not necessarily cgi/2015/151823.pdf. AUTHOR represent the views of Rice University’s 18. 49 U.S.C. 5101 et seq. Baker Institute for Public Policy. Rachel A. Meidl, LP.D., CHMM, is the fellow 19. The National Academies of in energy and environment at the Baker Sciences, Engineering, and Medicine, Safely © 2019 Rice University’s Baker Institute Institute. She was previously appointed for Public Policy Transporting Hazardous Liquids and Gases deputy associate administrator for the in a Changing U.S. Energy Landscape Pipeline and Hazardous Materials Safety This material may be quoted or (Washington, D.C.: The National Academies Administration, an agency of the reproduced without prior permission, Press, 2017), https://www.nap.edu/ U.S. Department of Transportation. provided appropriate credit is given to catalog/24923/safely-transporting- the author and Rice University’s Baker Her research focuses on the intersection hazardous-liquids-and-gases-in-a- Institute for Public Policy. between domestic and international policy changing-us-energy-landscape. and law as it relates to the transboundary Cite as: 20. Ibid movement of hazardous wastes; upstream Meidl, Rachel A. 2019. Is There a 21. The National Academies of Sciences, and end-of-life management of byproducts Correlation between Vapor Pressure Engineering, and Medicine, under the and the Severity of Crude Oil and wastes; and alternative and renewable auspices of the Transportation Research Transportation Incidents? Issue Brief energy, among other issues. no. 03.20.19. Rice University’s Baker Board, conducted a study in late 2015 due Institute for Public Policy, to the heightened concerns about whether Houston, Texas. the domestic energy revolution was placing stress on the transportation system that https://doi.org/10.25613/4s0t-9w41 would sacrifice safety. Modes of transport studied were maritime, highway, pipeline, 8