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NACD files comments on loading/unloading notice

NACD files comments on loading/unloading notice

The National Association of Chemical Distributors (NACD) has expressed support for performance standards to address hazmat product loading and unloading and recommends that reasonable standards be made part of the Hazardous Materials Regulations (HMR).

NACD said it also recommends that the standards only apply to bulk packagings with a capacity of 3,000 liters (about 793 gallons) or greater and that the responsibilities for developing and implementing the procedures are clearly apportioned between facilities and carriers.

In addition, NACD is asking the Pipeline and Hazardous Materials Safety Administration (PHMSA) to make sure that the standards are not prescriptive and duplicative of other existing regulations, but based instead on the level of hazard presented.

The NACD filed the comments on a PHMSA notice and request for comments on the establishment of recommended practices for loading and unloading operations involving bulk hazardous materials.

PHMSA is pursuing the issue based on a review of incident data, which shows that one-quarter to one-half of all serious hazardous materials incidents over the past decade may be associated with loading and unloading operations involving bulk packagings. In addition, the National Transportation Safety Board and the Chemical Safety and Hazard Investigation Board have suggested safety enhancements in this area, NACD pointed out.

NACD also commented that under the current HMR, PHMSA and the Department of Transportation (DOT) only have the authority to regulate loading and unloading functions when the carrier personnel is present, resulting in a regulatory gap that leads to inconsistent regulation over multiple jurisdictions, compromised safety, and a lack of incident data for DOT as the they do not have the authority to collect data if an incident occurs without carrier personnel present.

"The most important element of any new rule on loading and unloading must include an expansion of DOT authority to regulate these functions," said Jennifer Gibson, NACD vice-president of government and public affairs. "Only with strong federal authority can a uniform set of standards for loading and unloading of bulk packagings even be achievable."

More information about the PHMSA notice is online at

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