NTTC Submits Comment Letter to PHMSA on Hazardous Materials Proposed Rulemaking
On December 4, the National Tank Truck Carriers (NTTC) submitted a letter to William Schoonover, Associate Administrator for Hazardous Materials Safety of the Pipeline and Hazardous Materials Safety Administration (PHMSA), in response to an Advanced Notice of Proposed Rulemaking (ANPRM) on Hazardous Materials: Modernizing Regulations To Improve Safety and Efficiency. This ANPRM is identified by Docket number PHMSA–2019–0031 (HM–265A) in the Federal Register.
In the ANPRM, PHMSA requested information from stakeholders on 46 distinct topics that may be modernized within the Hazardous Materials Regulations and improve efficiencies while maintaining or improving a current high level of safety. PHMSA periodically revises the HMR based on changing economic, technological, and safety conditions. “As new technologies are developed, understanding of the risks inherent in the transportation of hazardous materials may change. New technologies can potentially provide new opportunities to improve packaging, hazard communication, and incident minimization,” said the ANPRM.
Of the 46 topics raised by PHMSA for stakeholder feedback, NTTC responded to 15 of them, with topics being addressed including carrier maintenance of Emergency Response Information; basic oil spill response plans; cargo tank thickness and leakage tests; emerging technologies; and definitions and experience for Registered Inspectors and Design Certifying Engineers. NTTC advocated for common sense solutions to proposed regulations changes, emphasizing repeatedly that, “Safety is at the heart of everything we do.” As an example, NTTC urged PHMSA to create a new option allowing more aspiring Registered Inspectors to qualify for their position having successfully completed a training course with evaluations and actual inspection and testing or assembly of a cargo tank specific to the person’s certification. In the letter, NTTC also strongly advocated for the authorization of electronic shipping papers given the advancements made in emerging technologies to streamline information flow.
The letter can be found in its entirety on the NTTC website by clicking here. NTTC staff will monitor potential Hazardous Materials Regulations changes in the future, and will announce those changes to members when updates are available.