ARLINGTON, Va., April 28, 2011 /PRNewswire-USNewswire/ -- NACD has serious concerns about the Pipeline and Hazardous Materials Safety Administration's proposed rule to prohibit the transportation of flammable liquids in external product piping, known as wetlines, on Department of Transportation specification cargo tank motor vehicles.
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"The primary concern is that such a rule would be difficult to enforce and would interfere with distributors' ability to deliver products to their customers. If adopted as proposed, the rule would allow a residue quantity of no more than one liter (0.26 gallon or 33 ounces) to remain in each pipe. It would be difficult for roadside inspectors to check these pipes to verify that they contain only these minimal amounts, and these inspections would create additional complications," wrote NACD Vice President of Government Affairs Jennifer Gibson in the comments.
NACD believes that the cost of adopting the NPRM would not justify the limited benefits. "In addition to the problems with inspections and product delivery, there would be costs of phasing out and retrofitting the tanks, including the time the vehicles would be out of service while this is done and the safety risks to the technicians completing the retrofits," wrote Gibson.
For a copy of the full comments, visit http://www.nacd.com/advocacy/comments.aspx.
NACD and its 390 member companies are vital to the chemical supply chain providing products to over 750,000 end users. They make a delivery every five seconds while maintaining a safety record that is more than twice as good as the safety standards set by DOT. NACD members are leaders in health, safety, security, and environmental performance through implementation of Responsible Distribution, established in 1991 as a condition of membership and is a third-party verified management practice. For additional information on our members, their safety record or NACD, visit NACD's website — http://www.nacd.com.
Contact: Matthew Glaser, 703/527-NACD(6223)
SOURCE National Association of Chemical Distributors (NACD)
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