Newsletter

With the Government Affairs Subcommittee (GAS) being newly added to the EGHSS Committee, we look to highlight its work and how it can play a major role in promoting ILTA’s advocacy agenda. Philip Squair serves as co-chair for GAS and brings decades of experience in government affairs, working as an advocate in the energy industry before coming to Colonial Pipeline where he has been for almost two years.   

We interviewed Philip and got his perspective on how legislative and regulatory advocacy is important to ILTA and its members.

Over the last decade, there has been a rise in drone usage at bulk liquid terminal facilities throughout the U.S. and the world.  Of course, with new technology comes both advantages and disadvantages as terminals continue to grapple with the changing physical security landscape at their facilities.

Brent Weber, a recent appointment to the ILTA Board of Directors, has served as President and CEO of Intercontinental Terminals Company (ITC) since 2021. A graduate of Louisiana State University, Brent has over 25 years of experience, a career that has ranged from organic and inorganic manufacturing management to sales and marketing. 

We recently had the opportunity to interview Brent about his career and his engagement with ILTA.

Dear Assistant Secretary Parker,

On behalf of the Employers Emergency Response Rulemaking Coalition (“Coalition”), I am submitting the following comments on the Occupational Safety and Health Administration’s (“OSHA”) Notice of Proposed Rulemaking (“NPRM”) for a new “Emergency Response Standard,” to replace the existing “Fire Brigades Standard,” 29 C.F.R. § 1910.156, Docket No. OSHA-2007-0073, published in the Federal Register on February 5, 2024.

INTRODUCTION

The Employers Emergency Response Rulemaking Coalition is composed of a broad array of industries impacted by OSHA’s proposed rule. The Coalition is comprised of multiple organizations, including trade associations, representing thousands of facilities located across the United States. Included among its members are companies in petroleum refining, chemical and petrochemical manufacturing, liquid terminal operations, agriculture, aerospace and defense, and other industries. Coalition members are leaders in safety and privately embedded emergency response programs that have a substantial interest in the outcome of OSHA’s rulemaking, as it will have a significant impact on how they manage such programs.

For years, Coalition members have voluntarily implemented effective emergency response programs. In that time, our members learned valuable lessons about the practices and policies that most effectively prevent and mitigate risks to our emergency responders. The comments we share represent the collective wisdom of employers and the employees who respond to emergencies. Our objective is to ensure that OSHA’s Emergency Response Standard effectively protects the safety and health of employees, volunteers, and the surrounding community, utilizing the most reasonable set of requirements possible.

Attached below is a copy of the full comments.

Dear Commissioner LaTourette,

On behalf of its membership, the International Liquid Terminals Association (ILTA) is seeking clarification regarding the New Jersey Discharges of Petroleum and Other Hazardous Substances regulations.

Founded in 1974, ILTA represents 80 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. ILTA’s membership also includes about 400 companies that supply equipment and services to the terminal industry.

Regarding the regulation, the preamble states that there is no requirement to implement mitigation measures identified in the climate resiliency plan. N.J.A.C 7:1E-4.12b requires that major facilities identify measures to mitigate the impacts of climate change identified in the analysis required by the proposed rule, to identify those mitigation measures that are deemed to be feasible, and to develop an implementation schedule for those measures.

It looks like the Department is requiring that facilities conduct an assessment and establish an implementation schedule, while the preamble states that the proposed rule does not require the owner or operator to implement mitigation measures.

We are asking the Department to clarify the mitigation implementation requirements for the climate resiliency plan, and whether the plan needs to be certified by NJ Certified Professional Engineer. We would also like to know what format is required for the climate resiliency plan, and whether it needs to be integrated into DPCC/DCR or can be a standalone plan.

Please do not hesitate to reach out to me if you have any questions.

Respectfully,
Leakhena Swett
President
International Liquid Terminals Association