Newsletter

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.

The International Liquid Terminals Association (ILTA), submit these comments responding to the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements Notice of Proposed Rulemaking (NPRM) published by the Cybersecurity and Infrastructure Security Agency (CISA) in the Federal Register on April 04, 2024. ILTA represents 82 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. For this reason, CIRCIA’s reporting requirements are of special interest to ILTA.

Download the comments below.

About 18 years ago, Mitchell Garner was searching for a career that had meaning, discipline and a place where strong bonds could be developed. He ended up accepting a position as an industrial firefighter for a company in Corpus Christi, Texas, where he and his colleagues were resident contractors to major oil and gas companies along the Gulf Coast.

“That career opportunity opened me to a world of knowledge about industry operations and industrial safety,” said Garner.

Years later, he transitioned to a terminal company in the Houston area where he spent nine years in their EHS department. Today, as Regional Manager of Safety and Emergency Response for LBC Tank Terminals, Garner truly enjoys the work he does.

The American Fuel & Petrochemical Manufacturers (AFPM), the International Liquid Terminals Association (ILTA), and The Fertilizer Institute (TFI) (hereinafter, Associations) submit these comments responding to the Cybersecurity in the Marine Transportation System Notice of Proposed Rulemaking (NPRM) published by the U.S. Coast Guard (USCG) in the Federal Register on February 22, 2204.  ILTA represents 82 commercial operators for 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 vegtable oils.

On Tuesday, May 7, ILTA held its Annual ILTA Safety Awards Presentation and Breakfast to honor 28 terminal member companies that achieved outstanding safety performance in 2023.

To receive the 2024 ILTA Safety Excellence Award, companies were required to score in the top two quartiles for both the 20 question self-assessment survey on leading indicators and the lagging indicator survey based on OSHA Form 300A.  This year, 52 companies participated in the safety survey, representing 70 percent of our membership.