NACD Submits Comments, Raises Concerns on Rail Tank Car Proposal

The National Association of Chemical Distributors yesterday filed comments with the Federal Railroad Administration on an April 1, 2008, notice of proposed rulemaking to improve the safety of rail tank cars transporting poison inhalation (PIH) materials. In the comments, NACD expresses support for the goal of enhancing the safety and security of hazardous materials transportation, but raises concerns about the increased costs, disruptions of commerce, and increased exposure to security risks that would result from some of the proposals.

On the proposal to require a maximum speed limit of 30 mph for PIH tank cars that do not yet meet new performance standards and are operating in non-signaled territory, NACD stated, "There is no guaranty that this proposal would increase safety, but it would certainly increase security risks. The proposal is contrary to the important objective of having these materials in transit for as short of a time period as possible. It would be much easier for a terrorist to track and target a train moving at 30 mph than to track one moving at 50 or 60 mph. At a time when stringent new regulations to increase security at fixed chemical facilities are being implemented, it would be particularly risky to increase the security exposure of PIH materials on the rails."

The other major concern NACD raises in the comments is the limited eight-year time frame for the mandatory replacement of all PIH tank cars to meet the new standards. "Such a short time frame could prematurely remove a significant number of tank cars from the service of transporting PIH materials. This would exacerbate the problem of a lack of shipping capacity for these critical materials and further raise prices for the vast majority of consumer goods on top of the increases already caused by skyrocketing fuel costs," NACD said in the statement. To view the full comments, go to

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