PHMSA describes the rule this way:
“This rulemaking would request information from industry that would consider whether additional requirements governing bulk loading and unloading operations are necessary. PHMSA has reviewed transportation incident data and findings of several National Transportation Safety Board and Chemical Safety Board accident investigations involving bulk hazardous materials loading and unloading operations, which suggest there may be opportunities to enhance the safety of such operations. In particular, PHMSA is examining what, if any, safety benefits would accrue from a requirement for persons conducting bulk loading and unloading operations to develop and implement operating procedures governing these operations. PHMSA has decided to publish a proposed rule instead of a pre-rule.”It will be interesting to see if they include any potential security actions in this rule. For example, before loading a truck or rail car, has there been an inspection done to determine if there has been any tampering done with the tank? The same kind of inspections should be done before bulk unloading as well. Additionally some sort of check needs to be done to confirm the material in the tank is what is described on the manifest.
Anyone want to bet about how long it will take PHMSA to get this rule into the Federal Register? My guess is somewhere between 2 weeks and six month.