The National Association of Chemical Distributors (NACD) stated in comments submitted to the US Department of Transportation that a proposed rule mandating tankcar design changes would significantly impact rail service and would shift hazardous materials transportation away from rail and onto the highways.

NACD’s comments addressed the proposed rule "Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains." Developed by the Pipeline and Hazardous Materials Safety Administration in the wake of several significant accidents involving tankcar shipments of crude oil in the United States and Canada, the proposed rule would create much stricter standards for the transport of hazardous materials by rail.

The association said in its comments that putting more hazardous materials shipments on the highways would result in increased opportunities for accidents and spills. Additionally, NACD noted that rail shipping prices will increase under the proposal, placing a greater burden on the chemical distribution industry.

The association expressed concern that the proposal covers all flammable liquids in high-hazard flammable trains (HHFTs), not just crude oil as originally intended. NACD Vice-President of Regulatory Affairs Jennifer Gibson said: "Because of the number of commodities covered and the broad definition of HHFTs, the number of customers covered will extend far beyond those shipping and receiving crude oil... This will have a substantial impact on the entire product supply chain in the United States."

NACD also called attention to the proposed 40 mile-per-hour speed limit for HHFTs. "An arbitrary national speed limit on all trains carrying flammable liquids would have wide-spread impacts throughout the entire national rail system as well as the economy as a whole,” Gibson said. “Speed restrictions applicable to HHFTs would directly impact the speed of all traffic on a rail line, which would increase transit times for all and create additional congestion."

Lastly, the association highlighted that the time frame for replacing all DOT-111 tankcars is too short. Warned Gibson, "The number of facilities in existence that are capable of building new rail cars and converting/retrofitting other tankcars is limited... A short time frame for replacement or retrofit would prematurely restrict a significant number of tankcars, and as a result, exacerbate the problem of the lacking shipping capacity."

To read NACD's complete comments, click on