NACD Comments, Letters and Testimony

June 2013

• NACD Comments on CFATS Personnel Surety Program
• Green Chemistry Alliance Comments on CA DTSC Economic Impact Statement on Safer Consumer Products Regulations
• Coalition Letter Opposing Industry Fees to Fund Safer Consumer Products Regulations

April 2013

• Industry Letter in Opposition to DOT Special Permit User Fees
• Industry Letter in Opposition to California Proposal to Allow State to Request Release of Customer Lists
• NACD Submits Tax Reform Comments to the House Committees on Small Business and Ways and Means
• Industry Letter Supporting the Improvement of the EPA's Science Advisory Board (SAB) and its committees

March 2013

• NACD Calls for Better Science at Federal Agencies
• Letter Chairman Shimkus and Ranking Member Paul Tonko from NACD calling for permanent authorization of the CFATS
• Industry Letter Raising Concerns about California Hazard Communication Standard

January 2013

• Industry Letter Urging Long Term Solution to East Coast Strike Dispute
• NACD Comments on Incorporation of Certain DOT Special Permits into the Hazardous Materials Regulations

December 2012

• Industry Letter to President Requesting Prevention of Port Strike

October 2012

• NACD Comments on California Safer Consumer Products Regulations

August 2012

• Industry Letter on the Need for Bipartisan TSCA Reform Legislation

July 2012

• American Alliance for Innovation Letter on Consideration of the Safe Chemicals Act
• Industry Letter in Support of H.R. 4078, the Red Tape Reduction and Small Business Jobs Creation Act
• Industry Letter Supporting Extention of All Expiring Tax Provisions and Pro-Business Tax Code Reform

June 2012

• NACD Comments on HM-218G Proposed Closure Instruction Notification Requirements

May 2012

• NACD Letter in Support of North American Metal Council Request for Extension of CDR Reporting Period

April 2012

• Industry Letter in Support of H.R. 7 Hazardous Materials Provisions
• Industry Letter to Office of Management and Budget on DHS Personnel Surety Program

November 2011

• NACD Comments on Proposal to Prohibit Federal Employee Participation in Trade Association Events

July 2011

• Industry Letter in Support of Effort to Curb EPA Regulatory Overreach
• Industry Comments to Office of Management and Budget on DHS CFATS Personnel Surety Program

June 2011

• NACD Letter to House Homeland Security Committee in Support of HR901 to Extend CFATS
• Comments on PHMSA HM-247 - Loading and Unloading of Cargo Tank Motor Vehicles

May 2011

• NACD Comments on DOT Electronic On-Board Recorder Proposed Rule
   
• NACD Letter to House Energy & Commerce Committee in Support of HR908 to Extend CFATS

April 2011

• NACD Comments to DOT Wetlines Proposed Rule
• NACD Letter to House Infrastructure Protection Subcommittee in Support of HR901 to Extend CFATS
• NACD Comments to the STB on Rail Competition

March 2011

• NACD Testimony before House Environment & Economy Subcommittee on Chemical Security Legislation to Extend CFATS
• NACD Comments on Highway-Rail Grade Crossing Clearance Proposed Rule
• NACD Comments on DOT Hours of Service Proposed Rule
     

January 2011
 

• Industry Appeal to PHMSA on HM-233B Final Rule on DOT Special Permits
• Industry Letter to House Oversight & Government Reform Committee Chairman Darrell Issa on DOT Special Permits and Approvals
• Industry Letter to OMB Director Jacob Lew on DOT Special Permits and Approvals

December 2010

• Industry Petition to FMCSA on the Hazardous Materials Safety Permit Program
• Industry Petition to PHMSA on Safety Fitness Criteria for DOT Special Permits and Approvals 

October 2010

• NACD Comments on EPA Inventory Update Reporting Proposed Rule

 July 2010

• NACD Comments on PHMSA HM-242 - Combustible Liquids

March 2010

• NACD Comments on OSHA's Proposed MSD Rule

• 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

February 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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