I can answer that question. We look at the requirement for risk assessment in terms of company rather than type. There are definitions under “key route” and “key train”, in terms of where the corridor or the route risk assessment must be conducted.
When the emergency directive was first issued, there were nine companies that fell under it. Among those, five had to submit risk assessments because of the volumes of dangerous goods they were carrying. Since then, the number of companies has fallen to four. The four companies that currently carry 10,000 or more loaded cars of dangerous goods are required to provide us with risk assessments.
The new rules require that the risk assessment be done, at a minimum, every three years. That is complemented by the requirement of the safety management system. If they are making significant changes to the operations, they are also required to conduct risk assessments, and to make those available upon request.