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Think Tank is the blog of the International Liquid Terminals Association that highlights the liquid terminal industry and its importance to the U.S. and world economy.


The Importance of Mitigating CERCLA Liability for Bulk Liquid Terminals Over PFAS Firefighting Foam Use

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From clothing to cookware, flame retardant per- and polyfluoroalkyl (PFAS) chemicals have become ubiquitous in our daily lives. For bulk liquid terminals specifically, PFAS compounds are used in aqueous film-forming foams (AFFF) or film-forming fluoroprotein foams (FFFP) foams because of their exceptional ability to create a stable and effective firefighting foam, particularly for extinguishing liquid fuel fires, such as those involving gasoline, jet fuel, or oil.

Due to their near-indestructability and persistence in local environments where they are used, however, states and the federal government are increasingly focusing on the environmental and public health consequences from the use of PFAS-based products. In March 2024, the Senate Environment & Public Works Committee held a hearing on, “Examining PFAS as a Hazardous Substance.” One month later in April, the Environmental Protection Agency (EPA) issued the first-ever national, legally enforceable drinking water standard to protect communities from exposure to harmful PFAS, while also finalizing a rule to designate two widely used PFAS – PFOA and PFOS – as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund.

Liquid Terminals will Serve Today’s Fuel Needs and be Tomorrow’s Hydrogen Hubs

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Dr. Kathryn Clay, who is president of the International Liquid Terminals Association and holds a PhD in Physics from University of Michigan, knows a little bit about the world energy picture. Recently she spoke about the current and future outlook for fuels during a panel at the U.S. Energy Association’s Fifth Annual Advanced Energy Forum.

While liquid terminals may operate behind the scenes, they play a vital role in the world energy supply chain and are critical to getting fuels, agricultural products and other bulk liquid commodities where they need to be and when they need to be there. Kathryn told the audience that the U.S. could be a significant exporter of hydrogen produced from renewables if we can get permitting right.

Superfund Is Not the Way to Regulate Bulk Terminal Firefighting Foam

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Last week, the International Liquid Terminals Association (ILTA) filed comments with the Environmental Protection Agency on a proposal to regulate PFAS-containing aqueous-film forming foam (AFFF) under the under the nation’s Superfund law (Comprehensive Environmental Response, Compensation & Liability Act of 1980).

Biden Administration Looking to Require COVID-19 Vaccines for Private Sector

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On September 9th, President Biden directed OSHA to issue a new Emergency Temporary Standard that would require many employers to provide paid time for employees to get and recover from getting vaccinated. The implementation of the “soft” vaccine mandates, i.e., requires their employees to either be fully vaccinated or get weekly COVID-19 testing, as well as issuing new Executive Orders requiring federal contractors to implement “hard” vaccine mandates. 

ILTA Gearing Up for Fall EHSS Meeting

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ILTA will host its next Environment, Health & Safety and Security Committee Meeting August 30-September 2 via Zoom . The EHSS meetings serve as a platform for ILTA terminal members to share with and learn from their peers as well as hear from outside experts on matters of importance to the bulk liquid storage industry.  Over the four-day event, ILTA terminal members can engage with one another on some of the most pressing issues facing the sector under the new Biden administration and the ongoing pandemic.