Government Affairs Brief

On October 13, 2026, ILTA submitted comments opposing the Petition for Reconsideration filed by a coalition of states seeking review of Preemption Determination No. PD-42(R). ILTA previously submitted comments supporting Exxon Mobil Corporation's application and continues to support PHMSA's determination that the Hazardous Materials Transportation Act ("HMTA") preempts the state common-law duties at issue. Please see the comments below.

On behalf of the American Fuel & Petrochemical Manufacturers (“AFPM”), American Petroleum Institute (“API”), American Chemistry Council (“ACC”), and International Liquid Terminals Association (“ILTA”), we are pleased to submit these comments on OSHA’s proposal to modify the fall protection requirements in the Walking-Working Surfaces standard that apply to fixed ladders that extend more than 24 feet above a lower level. 91 Fed. Reg. 17,165 (Apr. 6, 2026) (“the NPRM”).

The American Petroleum Institute (API), the American Fuel & Petrochemical Manufacturers (AFPM), and the International Liquid Terminals Association (ILTA) (collectively, “the  Associations”) respectfully submit these comments in response to EPA’s Advance Notice of  Proposed Rulemaking seeking to reconsider key provisions of the 2024 CWA Hazardous  Substances Facility Response Plan (FRP) rule (40 CFR Part 118). The Associations represent  facilities across the petroleum, petrochemical, and liquid bulk terminal sectors that collectively  handle the majority of CWA hazardous substances subject to the rule.

The International Liquid Terminals Association (ILTA) appreciates the opportunity to provide comments on the proposed amendments to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Marine Tank Vessel Loading Operations (MTVLO) (91 FR 10559, March 4, 2026).

Founded in 1974, the International Liquid Terminals Association represents over 60 companies operating liquid terminals in all 50 states and in over 40 countries. Our members’ facilities provide critical links between all modes of transportation for liquid commodities, such as crude oil, petroleum products, chemicals, renewable fuels, fertilizer, vegetable oils and other food-grade materials that are central to the U.S. economy. Terminals provide essential logistics services that spur trade both within the United States and connect the U.S. economy with overseas markets. 

The International Liquid Terminals Association (ILTA), submit these comments responding to the Advance Notice of Proposed Rulemaking (ANPRM) published by the Pipeline and Hazardous Materials Safety Administration (PHMSA) in the Federal Register on December 04, 2025. ILTA represents more than 60 commercial operators of over 600 aboveground liquid storage terminals that handle a wide range of liquid commodities, including crude oil, refined petroleum products, chemicals, fertilizers, animal fats, and vegetable oils. Many of these terminals operate under PHMSA’s Hazardous Materials Regulations (HMR). For this reason, PHMSA’s potential revisions to the HMR regarding highly automated transportation systems are of special interest to ILTA.

ILTA is concerned with this ANPRM’s provisions on shipping papers, hazard communications, packaging, and security plans & in-depth training, with an emphasis on the negative impact this ruling could have on smaller terminal operators.