NACD Comments and Testimony

March 2010

• Comments on PHMSA HM-208H - Proposed Rule to Increase HazMat Registration Fees
   
• NACD Letter to Senate Homeland Security Committee in Support of S. 2996, the Continuing Chemical Facilities Antiterrorism Security Act and in Opposition to IST

Febuary 2010

• Comments on DOT HM-233A - Incorporation of Special Permits into the HMR

December 2009

• NACD Comments on OSHA Globally Harmonized System (GHS) of Classification and Labeling of Chemicals

November 2009

• NACD Letter to House of Representatives on H.R. 2868, the Chemical and Water Security Act 

October 2009

• Joint Industry Letter to House Energy & Commerce Committee in Opposition to H.R. 2868, Chemical Facility Anti-Terrorism Act
  
• NACD Letter to House Energy & Commerce Committee on Chemical Facility Anti-Terrorism Act of 2009

September 2009

• Joint Industry Letter to House Energy & Commerce Committee on Chemical Facility Anti-Terrorism Act of 2009

June 2009

• Letter to House Homeland Security Committee on Chemical Facility Anti-Terrorism Act of 2009

March 2009

• Comments to the Surface Transportation Board on the Union Pacific Railroad Petition Requesting Limits on the Common Carrier Obligation to Transport HazMat Over Long Distances

November 2008

• Comments on PHMSA Proposal to Establish Procedures Under Enhanced DOT Inspection Authority
• Comments on PHMSA Proposal to Narrow the List of Materials Subject to HM-232 Security Plan Requirements

July 2008

• Comments on PHMSA Proposal to Increase HazMat Registration Fees
• Written Testimony to the Surface Transportation Board on the Common Carrier Obligation of Railroads to Transport HazMat

June 2008

• Comments on FRA Proposal to Improve the Safety of Railroad Tank Car Transportation of PIH Materials

May 2008

• Comments on FMCSA Proposal Regarding Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators

April 2008

• NACD Written Testimony to the Surface Transportation Board on the Common Carrier Obligation of Railroads

March 2008

• Letter to House Homeland Security Committee on Chemical Facility Anti-Terrorism Act of 2008
• Comments on PHMSA Recommended Practices for Bulk Loading and Unloading of Hazardous Materials in Transportation

September 2007

• Comments on HM233A - Special Permits to Include in the HMR

August 2007

• Comments on HM206F - Emergency Response Information Requirements

May 2007

• Comments on Appendix A of DHS Chemical Security Rule

February 2007

• Comments on TSA-PHMSA Rail Security Proposals
• Comments on DHS Chemical Security Advance Notice of Rulemaking

November 2006

• Comments on OSHA GHS Proposal
• Comments on HM-231 - DOT Packaging Requirements

October 2006

• Comments on HazMat Registration Fee Increase
• Comments on HM-215I – UN Harmonization

June 2006

• Testimony on Inherently Safer Technologies - Senate EPW

January 2006

• Comments on the Toxics Release Inventory Burden Reduction Proposed Rule

January 2005

• Comments Regarding the U.S. Drug Enforcement Administration's Interim Final Rule Establishing A New Category of List II Chemical Mixtures

December 2004

• Comments on a Proposed Rule Establishing Security Threat Assessment Fees for Hazmat Drivers

October 2004

• Comments to DOT on Enhancing Rail Transportation Security

NACD Testimony at Chemical Security Hearing, February 24, 2004

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July 2002

• Comments to DOT on HAZMAT Transportation Security Measures (PDF Document)

June 2002

• Comments to the U.S. Chemical Safety & Hazard Investigation Board RE: Reactive Chemical Accident Study (Word Document)

November 2001

• Comments to DOT to Withdraw HM-223 Proposal (Word Document)

July 2001

• Comments to U.S. Appeals Court in Tennessee on DOT HAZMAT Transportation Issues (Word Document)