Document R2jzoLD7QXvLkYVqQ2BZ2qjok

CM Chemical Manufacturers Association April 15,1996 Dockets Unit (DHM-30) Hazardous Materials Safety Research and Special Programs Administration U.S. Department of Transportation Washington, DC 20590-0001 Re: Transportation of Hazardous Materials By Rail; Miscellaneous Amendments; HM-216 Dear Sir or Madam: The Chemical Manufacturers Association Vinyl Chloride Panel submits these comments for consideration in the above referenced docket. The Panel recognizes that these comments are submitted after the close of the comment period, but would like the opportunity to go on record in support of the proposed changes to Sections 172.330 (a) (1). Specifically, the Panel maintains that the proposed changes to the tank car marking requirements in proposed Section 172.330 (a) (1) (ii) are appropriate to adequately inform transportation personnel and emergency responders about the tank car contents. By adjusting the marking requirements to allow the use of the "key words of the proper shipping name" or the proper shipping name or common name, the objective of the DOT'S hazardous materials regulations will be attained, without compromising safety. This amendment will enable shippers whose proper shipping name is amended to avoid the unnecessary costs of remarking the tank cars provided the marking contains the key words of the proper shipping name. The Panel appreciates the opportunity to submit these comments. Please call me at 703/741-5637 if you have any questions or need additional information. Sincerely, cc: Beth Romo James H. Rader Hasmukh C. Shah, Ph.D. Manager, Vinyl Chloride Panel CMA 111186 RatpontMeCare' 1300 Wilson Boulevard, Arlincton, VA 22209 Telephone 703-741-5000 Fax 703-741-6000 1 r APuSeComrtHwnt