Government Affairs Brief

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”).

Josh Etzel views ILTA as a vital connection point for the liquid terminals industry, helping members stay informed, engaged, and prepared in a rapidly changing environment. Through his Board service, he is focused on supporting strong leadership, strategic direction, and long-term value for members while helping elevate the essential role terminals play in global supply chains.

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.

From refinery operations to leading HSSE at JET Infrastructure, Todd’s career reflects growth, adaptability, and impact. Drawing on experience across refining and midstream, he focuses on strengthening safety, supporting people, and improving operations at every level.

His advice is simple: listen first, take on new challenges, and don’t be afraid to step outside your role. As the industry evolves, he stays focused on doing the work well and supporting his team.

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.