The Chlorine Institute - Facts about "C" Kits

MAFF has been notified by The Chlorine Institute that previous information posted may not be accurate.  We encourage our members to read and research.  Any questions, contact The Chlorine Institute at 703-894-4140 

The Chlorine Institute

1300 Wilson Boulevard, Suite 525 Arlington, VA 22209 
Ph: 703-894-4140
www.chlorineinstitute.org

The Facts About "C"-Kits & Secondary Containment­

A Memo to Michigan Firefighters & First Responders

TO: Michigan Firefighters and First Responders

FR: Frank Reiner, President- The Chlorine Institute

RE: The "C"-Kit is The Only Proven Approach to Tank Car Incidents

Firefighters and other first responders deserve the best and most accurate information about the equipment they need to safely and effectively respond to chlorine emergencies involving tank cars and trucks. Working closely with firefighters, railroads and federal regulatory agencies, The Chlorine Institute (CI), has always provided straight information to help ensure the safety of responders and the communities they serve.

A company interested in marketing a secondary containment product, TGO Technologies, Inc., has made statements that question the effectiveness and benefits of the CI "C"- Kit. The following information will help eliminate unnecessary confusion, and Cl includes sources so that all responders can judge the "C"-Kit for themselves.

  1. The "C"-Kit is specifically designed for dealing with leaks in and around pressure relief devices and angle valves, the "fittings" atop standard U.S. Department of Transportation-compliant tank cars and trucks.
  2. "C"-Kits have been used safely and successfully for more than 40 years, with more than5,500 kits in the hands of U.S. and Canadian responders.
  3. The TGO containment product has not received approval for use from the U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) or the Federal Railroad Administration. Please note PHMSA Administrator Cynthia L. Quarterman's May 6, 2013 letter to Nevada State Senator Moises Denis, which is quoted below. (A pdf of the letter is attached.)
  4. Thank you for your letter dated April 22, 2013. The Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Railroad Administration (FRA) are aware of the ChlorTanker device, which is a secondary containment top fitting protection product proposed by TGO Technologies, Inc. for rail tank cars transporting chlorine gas.
  5. In response to prior inquiries challenging the safety of the device, both PHMSA and FRA reviewed the ChlorTanker device and concluded that its product design is not approved for use under the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180) of the Pipeline and Hazardous Materials Safety Administration, U.S. Department of Transportation. We officially informed TGO Technologies of this conclusion last year and also referred TGO Technologies to the official design approval process referenced in our regulations, which requires approval, after review and testing, by the Association of American Railroads Tank Car Committee. To our knowledge, TGO Technologies has not initiated this process. In addition, despite our notification to the contrary, TGO Technologies continues to make public claims that its ChlorTanker design is fully compliant with the HMR, and we continue to receive complaints conveying concerns that TGO Technologies may be making misleading and false claims about the safety of the device.
  6.  TGO's claim that Cl is conducting a study comparing the C-Kit to secondary containment is false. Though Cl attempted an analysis, TGO's lack of cooperation made it impossible to proceed. No study is currently underway.
  7. Cl has no financial or proprietary interest in the "C"-kit and provides training free of charge through the CHLOREP (CHLORine Emergency Plan) and TRANSCAER® (Transportation Community Awareness and Emergency Response) programs.
  8. Training that covers the properties of chlorine, the use of respiratory and all other safety equipment, and the correct use of the C-Kit is absolutely essential for all responders and Cl is proud to have helped train thousands of responders over the years.
  9. CI's The Chlorine Institute Emergency "C" Kit Instruction Booklet for Chlorine Tank Car & Tank Trucks" also is available to responders free of charge. It carefully guides responders through every aspect of "C"-Kit use, including the need to pressure test cars. Note p. 12 of the booklet (Edition 9, january 2009):
  10. CAUTION: Prior to installing DEVICE 24, a pressure reading should be taken to ensure the tank is not liquid full. (This warning appears in the booklet in Boldface and Italics. DEVICE 24 is the Hood for Pressure Relief Device.)
  11.  In short, CI has been and will continue to be a strong and faithful partner to firefighters and responders throughout North America. We welcome your questions and comments. Please feel free to contact us directly through:

Ms. Robyn Kinsley
Director, Transportation & Incident Analysis
The Chlorine Institute
1300 Wilson Blvd. Arlington, VA 22209
703.894.4123 This email address is being protected from spambots. You need JavaScript enabled to view it.

PHMSA Administrator Cynthia L. Quarterman's Letter to Sen. Denis of NV.

  1. Administrator Quarterman's letter to Cl.
  2. Cl's Briefing Paper: "Emergency Kit 'C': Proven Equipment for Chlorine Tank Car/Tank Truck Emergency Response."
  3. CI's "just the Facts...About The C-Kit.
  4. PDF of the CI Kit "C" Instruction Booklet.