National Tank Truck Carriers recently submitted formal comments to the U.S. Department of Transportation (DOT) in response to a Request for Information, titled “Ensuring Lawful Regulation; Reducing Regulation and Controlling Regulatory Costs.”
This effort follows Executive Order 14219, “Ensuring Lawful Governance and Implementing the President’s ‘Department of Government Efficiency’ Deregulatory Initiative,” issued by President Trump on Feb. 19. In line with the order, the DOT sought input to identify existing regulations, guidance, and paperwork requirements that could be revised or eliminated to reduce regulatory burdens without compromising safety and security.
In its submission, NTTC identified 13 key regulatory areas as excessively burdensome and in need of reform. These suggestions have been crafted by NTTC members with approval by the Safety and Security Council.
“NTTC urges DOT and its modal agencies to pursue practical, data-driven reforms that embrace modern technologies and better align federal regulations with the operational realities of the tank truck industry,” Will Lusk, NTTC director of education and government relations, wrote in the nine-page letter.
“By eliminating unnecessary burdens, clarifying complex rules, and advancing risk-based frameworks, DOT can improve regulatory effectiveness while supporting innovation, safety, and economic growth.”
1. Electronic shipping papers
NTTC urged PHMSA to modernize regulatory provisions to permit electronic and telephonic communications, similar to those already allowed for rail. Proposed amendments to several sections of 49 CFR would authorize the electronic transmission and storage of shipping papers and certifications for hazardous materials shipments.
2. Reform hazmat truck requirements at highway rail-grade crossings
NTTC called for a risk-based approach to regulations requiring HAZMAT trucks to stop at highway-rail crossings. Carriers proposed exemptions for crossings deemed low-risk or where stopping poses safety concerns due to high traffic volumes.
3. Rear pulsating lights
The letter also argues for reformation of § 392.10 to enhance the visibility of tank truck trailers when braking. Many tank truck operators utilize exemptions to allow for the usage of these lighting systems and have found great success in reducing crashes. NTTC urges that § 393.25 be amended to authorize rear pulsating lights to the back of tank trucks.
4. Underride protection
NTTC opposed blanket mandates requiring underride guards on older tank trailers not designed for such equipment. They stressed that retrofit requirements should be informed by comprehensive risk analysis, real-world data, and stakeholder input.
5. Crash Preventability Determination Program
NTTC expressed concern about delays—often exceeding six months—in crash preventability determinations. These delays negatively affect carriers' relationships with clients and insurers. The letter also expressed concerns over the lack of a formal appeals process for disputed rulings.
6. Hours-of-service regulations
Carriers highlighted the complexity and burdens of Hours of Service (HOS) regulations, especially due to numerous exceptions and issues related to electronic logging devices (ELDs). They emphasized that many violations result from technical misunderstandings rather than unsafe driving behavior.
7. Qualification of drivers
NTTC argued that certain background check requirements are redundant for CDL-holders and add administrative burdens without tangible safety benefits. NTTC shared concerns over duplicative requirements given that for many large fleets, this process is typically outsourced to third party vendors.
8. Controlled substances and alcohol use and testing
NTTC endorsed a risk-based approach to drug testing. Carriers contended that mandatory testing in the absence of reasonable suspicion is overly burdensome and lacks justification based on evidence of risk.
9. Inspection, repair, and maintenance
NTTC recommended modernizing these provisions to reflect technological advancements in fleet operations, thereby reducing paperwork without compromising safety standards.
10. FRP and special metal cargo tanks
Certain cargo tanks constructed with fiber-reinforced plastic (FRP) or special metals under DOT 407 specifications continue to operate under long-standing special permits or exemptions. Despite a demonstrated safety record, carriers and manufacturers have to consistently apply for renewals since the fall outside of the language of 49 CFR Part 178 Subpart J. These renewals create unnecessary administrative burdens and regulatory uncertainty.
11. Replacement fuse requirements
NTTC stated that 49 CFR § 393.95(b) is increasingly outdated, noting that modern truck electrical systems require professional service and that drivers are not equipped to replace fuses in the field.
12. Emergency response information
NTTC proposed transitioning from paper ERI to digital formats accessible via QR codes, which would provide more practical and timely information to emergency responders.
13. Cargo tank registered inspector definition
The letter called for clarifications on the experience requirements and a more precise definition of qualifying engineering degrees. NTTC also proposed a new qualification category for inspectors without a high school diploma or three years of experience.