OTTAWA, Ont. — The Canadian Trucking Alliance (CTA) is questioning the rationale for a proposed regulation on wetlines, suggesting that the current regulatory proposal should be withdrawn. CTA made official comments to the US Pipeline and Hazardous Materials Safety Administration (PHMSA) on behalf of Canadian transborder tank truck carriers.

Wetlines are metal tubes that run along the underbelly of tank trucks used to transfer fuel into and out of the tanker. Wetlines are known to contain residue amounts of liquids following the loading process. PHMSA has proposed that for tank trailers containing flammable liquids, a limit of one litre of residue per line should be allowed, or the tank trailer should be fitted with bottom damage protection devices.

In its analysis of the proposed regulation, Hazardous Materials: Safety Requirements for External Product Piping on Cargo Tanks Transporting Flammable Liquids, CTA concluded that the cost-benefit study accompanying the proposal did not present any clear evidence to justify regulation. CTA noted that a previous attempt to regulate wetlines in 2006 was also withdrawn because it could not be justified on a cost-benefit basis.  

“All proposed regulations require a careful analysis of the costs and benefits associated with the proposal, as well as a consideration of policy alternatives,” said CTA vice-president, Ron Lennox who worked with tank truck carriers in developing CTA’s position. “It is the responsibility of CTA to work with regulators and in the United States with ATA and others in the industry to develop regulations designed to meet safety objectives; in this instance, the proposed regulation falls short.”

In addition to concerns surrounding the cost-benefit analysis, CTA raised questions about the lack of industry experience with proposed wetline purging methods, and with the absence of a discussion in the proposed rule about safety hazards associated with retrofitting tank trailers.

“CTA is a strong advocate of reasonable regulations designed to enhance safety as evidenced by our history of supporting, and in some cases, initiating regulatory change,” Lennox said. “However, this proposed wetline regulation is deficient in a number of fundamental aspects and it is CTA’s position that it should be withdrawn.”