Category Archives: Transportation

Gearing up for the Impending ELD Mandate

By Scopelitis, Garvin, Light, Hanson & Feary (Scopelitis)

The December 18, 2017 compliance deadline for the Federal Motor Carrier Safety Administration’s electronic logging device (ELD) service is looming for the transportation industry. It is up to carriers to ensure their devices are compliant. Learn more in The Transportation Brief, produced by GCCA’s transportation law services provider Scopelitis. Continue reading

CARB Initiates Survey of Cold Storage Facilities in California

Written by GCCA Vice President of Government and Legal Affairs Lowell Randel

On October 27, 2016, the California Air Resources Board (CARB) initiated a Cold Storage Warehouse Survey that applies to refrigerated warehouses in the State of California. CARB is requesting this information to improve the agency’s emission inventory and to evaluate the feasibility of establishing stationary Transportation Refrigeration Unit (TRU) engine operating time limits to reduce air pollution emissions from TRUs, including greenhouse gasses (GHG), diesel particulate matter (PM), and nitrogen oxides (NOx). Continue reading

Coast Guard Posts FAQs on Container Weight Regulations

On March 2nd, the U.S. Coast Guard posted information related to the upcoming compliance deadline for verified gross weights under the Safety of Life at Sea (SOLAS) convention. The FAQ gives a background on the SOLAS requirements and how the U.S. government will be enforcing the regulation. The Coast Guard will be the enforcing agency for SOLAS regulations when they become effective on July 1, 2016. A copy of the FAQ can be found here.

GCCA Leads Coalition Comments on DHS CFATS Program

On November 30th, the Global Cold Chain Alliance led a coalition of industry organizations in providing comments to the Department of Homeland Security regarding the Chemical Facility Anti-Terrorism Standards (CFATS) Program. DHS sought public comment specifically on Appendix A of the CFATS Program, which deals with the chemicals of interest that bring a facility under the program’s jurisdiction. Currently, facilities with over 10,000 pounds of ammonia are required to submit a Top Screen under the program.

The coalition’s comments request that DHS remove anhydrous ammonia used in industrial refrigeration facilities be removed from Appendix A. The coalition stressed that the current requirement for facilities with over 10,000 pounds of anhydrous ammonia used for closed-circuit refrigeration systems to file a Top Screen under the CFATS program is duplicative and unnecessary. The only security issue stated in the CFATS program for anhydrous ammonia is “Release – Toxic”. This risk is already sufficiently covered by the Environmental Protection Agency’s Risk Management Program (RMP) and the Occupational Safety and Health Administration’s Process Safety Management (PSM) regulations. RMP and PSM require facilities to develop detailed plans that address the risks of a toxic release of ammonia used for closed-circuit refrigeration systems.

A copy of the comments submitted to DHS is attached to this post.

Multi Organization Comments CFATS Appendix A – November 2015.pdf

Senate Passes Surface Transportation Legislation

On July 30th, the Senate completed its consideration of reauthorization of surface transportation programs entitled: “Developing a Reliable and Innovative Vision for the Economy Act (DRIVE Act).” The bill had bipartisan support and passed on a vote of 65-34. The bill authorizes transportation programs for six years, but only provides funding for the first three. How to fund programs under the bill remains a sticking point, and leaders in the House of Representatives have expressed strong concerns with the Senate approach. The House has not advanced a comparable long term authorization package to date.

With transportation authorizations due to expire at midnight on July 30th, the House passed a three month extension earlier this week to give additional time to work out a longer term deal. Shortly after passing the DRIVE Act, the Senate also passed the three month extension proffered by the House. President Obama is expected to sign the three month extension, giving Congress until the end of October to reach agreement on a longer term deal. This will be the 35th extension of authority for surface transportation programs since 2009.

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