Monday, April 28, 2008

Comments on Rail Security and Safety Rules – 4-25-08

There are currently three rules recently published in the Federal Register dealing with the security and safety of rail transportation of various hazardous chemicals. All three rules are in the comment period. Generally speaking the comments made on each of these rules are posted on the web site. Periodically we will review the comments posted on that site.

PIH Tank Car Rule

Comments are to be submitted by June 2, 2008. To date there are two comments posted since the proposed rule was published. One comment was made by a college student and the other was made by a company, TGO Technologies that has a design for an improved chlorine railcar. Sarah V of Westfield State College was generally supportive of the attempt to increase the safety of railcars transporting TIH chemicals.

Route Security Analysis Rule

Comments are to be submitted by May 16, 2008. PHMSA has added two documents to the docket since the interim final rule was published; an environmental assessment and a regulatory assessment. No other comments have been posted.

Appeal of Adverse Rail Routing Decisions Rule

Comments are to be submitted by June 16, 2008. No comments have been posted since the proposed rule was published.


PHMSA requested input on a series of specific questions addressed to the railroads, the chemical industry and the water treatment industry. While there is still some time before the close of the comment period, it is disappointing that there have been no replies to date from those industries in almost a month since the rule was published.

While it has been just a little more than a week since the route analysis rule was released, this is a very controversial rule. There have been a number of adverse comments in the press from a number of organizations. None of those comments have made it to this docket.

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