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NACD Comments and Testimony
July 2010
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
• Download PDF
• Download Word
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)
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