International Vessel Operators Dangerous Goods Association

Memo

VOHMA has filed comments on the US DOT HM-208H Hazardous Materials Transportation; Registration and Fee Assessment Program - Notice of Proposed Rulemaking. This NPRM proposes to amend the HMR to increase the registration fee to provide funding for the HMEP fund for the 2010-2011 registration year as authorized by the Hazardous Materials Transportation Safety and Security Act of 2005, to the amount of $28,000,000, representing an immediate increase of over 200%.

The VOHMA comments specifically address the impact of the increase of the registration fees on the intermodal carrier spectrum, annual budgets and the competitive market in these fragile financial times. Click here to view the comments. In the comments, John Currie, VOHMA Administrator and Chief Technical Officer noted the following:

• "If there is to be an increase in fees, the fee assessment should be more equitably determined across the intermodal carrier spectrum based once again on risk analysis and the commodity flow studies already in place which would quickly correlate to volumes.
• Annual budgets are prepared by businesses several months in advance of their implementation and are based on the expenses anticipated to be incurred in the year to follow. Thus budgets for the 2010 registration year were based on the annual fees in effect in late 2009. In these difficult financial times, many of those budgets were trimmed to the bare essentials and for some companies included elimination of jobs, consolidation of services, and even cancellation of memberships in trade associations.
• US DOT Pipeline Hazardous Materials Association (PHMSA) should consider the fact that vessel operators use large quantities of petroleum fuels and are finding it increasingly difficult to remain competitive and efficient in this costly energy environment. In recent months, many marine transport associated businesses have filed for legal protection with some even closing down.
• US DOT PHMSA should use data compiled through commodity flow studies and emergency plans to determine the skill level training required for first responders and temper the HMEP grants program with fiscal restraint based on discretionary evaluation rather than entitlement."

VOHMA, recently renamed the International Vessel Operators Dangerous Goods Association, Inc. (IVODGA) is a United States based international association, with a membership comprised of twenty-eight ocean common carriers, operating under the flags of several nations, with the purpose of serving the domestic and international Trades in matters pertaining to vessel and intermodal transport of hazardous cargoes. The primary goal of VOHMA is to advocate and promote safe, consistent, and cost-beneficial transport of such cargoes based upon discussion and evaluation of issues impacting maritime operations and interconnecting feeder systems, and to develop consensus positions on all issues which may have a significant impact on transportation safety.