May 22, 2017· Comment from American Coatings Association· PHMSA-2016-0077-0069
The American Coatings Association (ACA) hereby submits comments to Advanced Notice of Proposed Rulemaking (ANPRM) Docket No. PHMSA-2016-0077 (HM-251D) regarding the volatility of unrefined petroleum products and Class 3 materials. We appreciate the opportunity to provide comments on this topic. ACA is a voluntary, nonprofit industry trade association representing some 250 paint and coatings manufacturers, raw materials suppliers and distributors. The membership collectively produces about 90% of the total national volume of paints and allied products. ACA members transport these products globally in all modes. At least half of the finished products meet the requirements of hazardous materials that are regulated under the HMR.