Newsletter

We, the undersigned associations, write to you regarding provisions in S. 1790 and H.R. 2500, the “National Defense Authorization Act for Fiscal Year 2020,” addressing the regulation of per- and polyfluoroalkyl substances (“PFAS”).

We appreciate the bipartisan approach taken thus far and recommend that any Congressional action enable the appropriate agencies to carry-out the risk-based approach established in existing U.S. environmental law and policy. As warranted, we support the regulation of specific PFAS chemicals, and it is important that Congress prioritize the cleanup of contaminated sites to protect communities. As the Senate and the House of Representatives begin their conference deliberations, we urge you to oppose those provisions that would circumvent existing, well-established regulatory processes, predetermine outcomes using inadequate scientific data, and potentially inhibit effective cleanup of those PFAS that are of the greatest concern.

The International Liquid Terminals Association (ILTA) is pleased to provide comments on North Dakota’s and Montana’s request for a preemption determination on the July 2019 Washington State law Crude Oil by Rail–Vapor Pressure. ILTA asks that the Pipeline and Hazardous Materials Safety Administration (PHMSA) find that Washington State’s law limiting the Reid Vapor Pressure of crude oil is preempted by Federal Hazardous Materials Regulations (HMR). The state law is also in conflict with the Dormant Commerce Clause of the U.S. Constitution, which prevents states from interfering with interstate commerce between the states.

We, the undersigned associations, write to you regarding provisions in S. 1790 and H.R. 2500, the “National Defense Authorization Act for Fiscal Year 2020,” addressing the regulation of per- and polyfluoroalkyl substances (PFAS).

As the U.S. Senate and U.S. House of Representatives begin their conference deliberations, we urge you to voice support for those provisions that would lead to more expeditious cleanup at potentially contaminated sites, and oppose those provisions that would circumnavigate existing, well-established regulatory processes and predetermine outcomes using inadequate scientific data.

We, the undersigned associations, believe that Congress should act to address contamination associated with per- and polyfluoroalkyl substances (PFAS) in a manner that prioritizes cleanups over bureaucracy. For this reason, we oppose Amendment 440 offered by Reps. Kildee and Dingell, and Amendment 48, offered by Rep. Pappas, to H.R. 2500, the “National Defense Authorization Act for Fiscal Year 2020.” 

The International Liquid Terminals Association (ILTA) appreciates the opportunity to comment on the second installment of Mitigation Strategies To Protect Food Against Intentional Adulteration: Draft Guidance for Industry. ILTA is the leading representative of the bulk liquids terminal industry, with more than eighty-five-member companies. Many of our member companies store food-grade products in their facilities and are therefore subject to FDA’s comprehensive food defense regulations. We are pleased to play an active role in the regulatory process and share the following comments on the latest release of guidelines for Mitigation Strategies to Protect Food Against Intentional Adulteration: Draft Guidance for Industry.