Common Law Tort Claims Concerning Design and Marking of DOT Specification 39 Compressed Gas Cylinders, 39567-39571 [2012-16240]
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Federal Register / Vol. 77, No. 128 / Tuesday, July 3, 2012 / Notices
Lotus’s financial hardship, exacerbated
by the global recession; emergence of
competition in its market segment; and
the withdrawal of the Elise from the
U.S. market. Furthermore, Lotus states
the Evora’s advanced air bag system will
not comply with the higher speed 5th
percentile female belted occupant
(passenger side, fully forward seat
position) barrier crash test without
sourcing new components and
conducting a complete revalidation of
the system. Lotus previously believed
that Evora sales would have been
augmented by a new product using
substantially the same platform, upon
which compliance with the higher
speed 5th percentile female belted
requirements would have been
developed. However, Lotus states that it
stopped that development program due
to poor Evora sales and repositioning of
its business (moving from the entry
level premium segment to the high
performance, luxury sports car
segment).
Lotus states that the Evora cannot
meet the higher speed 5th percentile
female belted test requirements because
the Evora’s air bag electronic control
unit (ECU) does not have the capability
to monitor whether the seat belt is
buckled and its seat belt supplier does
not have a suitable buckle switch. A
buckle switch would allow the ECU to
fire only the first stage of the air bag
inflator for buckled occupants while
firing two stages for unbuckled
occupants, allowing the stiffness of the
air bag to be different for belted and
unbelted occupants. In order to
incorporate a buckle switch in the
Evora, Lotus states that a new air bag
ECU would need to be sourced,
calibrated, and validated; a new seat
belt system would need to be sourced;
and a complete series of development
tests would need to be conducted.
Lotus expects that this development
would cost over $4 million. Lotus states
that it does not have sufficient financial
resources to complete this development.
Lotus’s financial statements show that
from the period between April 2007 and
March 2010, the company experienced
losses of approximately $40 million.
With an exemption, Lotus predicts that
it would make a profit of approximately
$24 million between April 2010 and
March 2014. Without an exemption,
Lotus predicts its profit in the same
period would be reduced to $13 million.
However, Lotus contends that the
financial impact would be greater
because, without the exemption, Lotus
would withdraw from the U.S. market
and lose its market share, resulting in
intangible losses such as loss of brand
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image, complication of reentry into the
U.S. market in the future, and job losses.
Lotus states that it has considered
alternative means of compliance, but
these alternatives have been found to be
incapable of providing a solution. Lotus
states that it could not use a seat belt
buckle sensor from its current seat belt
supplier because the switch is
inadequate and there is not a suitable
ECU. Lotus states that it considered
moving the passenger seat rearward, but
concluded it would have to reevaluate
compliance with the 50th percentile
male tests in both the belted and
unbelted conditions which would result
in similar costs to those described
above. Lotus also states that it
considered fixing the passenger seat in
the mid-position, but concluded that
occupant ingress/egress would be
adversely affected and it would prevent
a 95th percentile occupant from fitting
in the passenger seat.
Lotus states that, while an exemption
is in effect, it will provide advice and
warnings in its owners’ manual
identifying the risks associated with
correct positioning of the seat belt and
sitting too close to the air bag.
IV. Completeness and Comment Period
Upon receiving a petition, NHTSA
conducts an initial review of the
petition with respect to whether the
petition is complete and whether the
petitioner appears to be eligible to apply
for the requested exemption. The agency
has tentatively concluded that the
petition from Lotus is complete and that
Lotus is eligible to apply for a temporary
exemption. The agency has not made
any judgment on the merits of the
application, and is placing a nonconfidential copy of the petition in the
docket.
The agency seeks comment from the
public on the merits of Lotus’s
application for a temporary exemption
from the higher speed 5th percentile
adult female belted barrier crash test in
S14.7 of FMVSS No. 208. We are
providing a 30-day comment period.
After considering public comments and
other available information, we will
publish a notice of final action on the
application in the Federal Register.
Issued on: June 26, 2012.
Nathaniel Beuse,
Director, Office of Crash Avoidance
Standards.
[FR Doc. 2012–16271 Filed 7–2–12; 8:45 am]
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DEPARTMENT OF TRANSPORTATION
Pipeline and Hazardous Materials
Safety Administration
[Docket No. PHMSA–2009–0017 (PD–34(R))]
Common Law Tort Claims Concerning
Design and Marking of DOT
Specification 39 Compressed Gas
Cylinders
Pipeline and Hazardous
Materials Safety Administration
(PHMSA), DOT.
AGENCY:
Notice of administrative
determination of preemption.
ACTION:
Applicable Federal Requirements:
Federal hazardous material
transportation law, 49 U.S.C. 5101 et
seq., and the Hazardous Materials
Regulations (HMR), 49 CFR parts 171–
180.
Modes Affected: All transportation
modes.
SUMMARY: Federal hazardous material
transportation law preempts a private
cause of action which seeks to create or
establish a State common law
requirement applicable to the design,
manufacture, or marking of a packaging,
container, or packaging component that
is represented, marked, certified, or sold
as qualified for use in transporting
hazardous material in commerce when
that State common law requirement
would not be substantively the same as
the requirements in the HMR. Federal
hazardous material transportation law
does not preempt a tort claim that a
packaging, container, or packaging
component that is represented, marked,
certified, or sold as qualified for use in
transporting hazardous material failed
to meet the design, manufacturing, or
marking requirements in the HMR or
that a person who offered a hazardous
material for transportation in commerce
or transported a hazardous material in
commerce failed to comply with
applicable requirements in the HMR.
FOR FURTHER INFORMATION CONTACT:
Frazer C. Hilder, Office of Chief
Counsel, Pipeline and Hazardous
Materials Safety Administration, U.S.
Department of Transportation, 1200
New Jersey Avenue SE., Washington,
DC 20590–0001 (Tel. No. 202–366–
4400).
SUPPLEMENTARY INFORMATION:
I. Application
AMTROL, Inc. has applied to PHMSA
for an administrative determination
whether the Federal hazardous
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materials transportation law 1 preempts
State common law tort claims that the
manufacturer of a DOT specification 39
compressed gas cylinder should have
designed the cylinder to resist rusting
and/or marked or labeled the cylinder
with warnings of the potential hazard of
rusting over time.
A DOT specification 39 cylinder is a
non-reusable (non-refillable) seamless,
welded, or brazed cylinder made of steel
or aluminum (having certain specified
characteristics), with size limitations
(depending on the service pressure of
the cylinder) and requirements for
manufacturing, minimum thickness of
the cylinder wall, openings and
attachments on the head of the cylinder,
and pressure and flattening testing. 49
CFR 178.65. Subsection 178.65(i)
provides that the cylinder must be
marked with certain information 2
including the specification number,
service and test pressure, date of
manufacture and a registration number
identifying the manufacturer, and:
—‘‘NRC’’ for ‘‘non-reusable container,’’ and
—the statement that ‘‘Federal law forbids
transportation if refilled’’ plus a statement
of the maximum civil and criminal
penalties applicable at the date of
manufacture.
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On January 30, 2009, PHMSA
published a notice in the Federal
Register inviting interested persons to
comment on AMTROL’s application. 74
FR 5723. As discussed in this notice, a
products liability lawsuit had been
brought against AMTROL and other
defendants by the survivors and next of
kin of Kenneth Elder (the ‘‘Elders’’) who
died on January 24, 2003, when a rusted
DOT specification 39 cylinder ruptured
after Mr. Elder placed the cylinder in
179 degree water.3
In response to AMTROL’s application
and the January 30, 2009 Federal
1 The Federal hazardous material transportation
law currently codified at 49 U.S.C. 5101 et seq. is
often referred to by the acronym ‘‘HMTA’’ for the
Hazardous Materials Transportation Act, Public
Law 93–633, 88 Stat. 2156, enacted January 3, 1975.
Prior to codification in 1994 (Pub. L. 103–272, 108
Stat. 745 (July 5, 1994)), the HMTA was set forth
at 49 App. U.S.C.A. 1801 et seq.
2 In this determination, the word ‘‘marking’’ is
used to refer to the information required to be
marked on a DOT specification 39 cylinder under
49 CFR 178.65(i)—to distinguish this marking from
a hazard class warning label (e.g.,
NONFLAMMABLE GAS) and a product sticker or
label that may contain the proper shipping name
and UN identification number required to be
marked on the filled cylinder by a person who
offers the filled cylinder for transportation in
commerce. See 49 CFR 172.301 et seq. and 172.400
et seq.
3 The Elders’ claims against AMTROL are
presently pending as a claim in bankruptcy in the
U.S. Court of Appeals for the Third Circuit which
has issued a stay pending PHMSA’s determination.
In re Amtrol Holdings, Inc. v. Kenneth Elder, No.
10–3273.
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Register notice, comments were
submitted by AMTROL, the Elders,
Thomas Wilson (a retired hazmat
shipper who occasionally acts as a
consultant), and the Gases and Welding
Distributors Association, Inc.
(GAWDA).4
II. Federal Preemption
A United States Court of Appeals has
found that uniformity was the
‘‘linchpin’’ in the design of the Federal
laws governing the transportation of
hazardous materials. Colorado Pub. Util.
Comm’n v. Harmon, 951 F.2d 1571,
1575 (10th Cir. 1991). Section 5125 of
Title 49 U.S.C. contains express
preemption provisions. As amended by
Section 1711(b) of the Homeland
Security Act of 2002 (Pub. L. 107–296,
116 Stat. 2320),5 § 5125(a) provides that
a requirement of a State, political
subdivision of a State, or Indian tribe is
preempted—unless the non-Federal
requirement is authorized by another
Federal law or DOT grants a waiver of
preemption under § 5125(e)—if
(1) Complying with a requirement of the
State, political subdivision, or tribe and a
requirement of this chapter, a regulation
prescribed under this chapter, or a hazardous
materials transportation security regulation
or directive issued by the Secretary of
Homeland Security is not possible; or
(2) The requirement of the State, political
subdivision, or tribe, as applied or enforced,
is an obstacle to accomplishing and carrying
out this chapter, a regulation prescribed
under this chapter, or a hazardous materials
transportation security regulation or directive
issued by the Secretary of Homeland
Security.6
Subsection (b)(1) of 49 U.S.C. 5125
further provides that a non-Federal
4 GAWDA describes itself as ‘‘a national trade
association representing the interests of some 600
distributors of compressed and cryogenic gases and
related supplies and equipment in the United States
and Canada,’’ some of which ‘‘fill, store, handle and
transport gases in DOT–39 compressed gas
cylinders.’’
5 Section 1711 of the Homeland Security Act of
2002 added the words ‘‘including security’’ to the
applicability provisions in 49 U.S.C. 5103(b)(1) and
the preemption provisions in § 5125(a) and (b)(1).
Otherwise, the 1994 codification of Title 49 and
subsequent editorial revisions and technical
corrections have not made any substantive changes
to these provisions since amendment of the original
HMTA in 1990. See Sec. 7122(a) of the Hazardous
Materials Transportation Safety and Security
Reauthorization Act of 2005, which is Title VII of
the Safe, Accountable, Flexible, Efficient
Transportation Equity Act: A Legacy for Users
(SAFETEA–LU), Pub. L. 109–59, 119 Stat. 1891
(Aug. 10, 2005), and Public Law 110–244 § 302(b),
122 Stat. 1618 (June 6, 2008).
6 These two paragraphs set forth the ‘‘dual
compliance’’ and ‘‘obstacle’’ criteria which are
based on U.S. Supreme Court decisions on
preemption. Hines v. Davidowitz, 312 U.S. 52
(1941); Florida Lime & Avocado Growers, Inc. v.
Paul, 373 U.S. 132 (1963); Ray v. Atlantic Richfield,
Inc., 435 U.S. 151 (1978).
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requirement concerning any of the
following subjects is preempted—unless
authorized by another Federal law or
DOT grants a waiver of preemption—
when the non-Federal requirement is
not ‘‘substantively the same as’’ a
provision of Federal hazardous material
transportation law, a regulation
prescribed under that law, or a
hazardous materials security regulation
or directive issued by the Department of
Homeland Security: 7
(A) The designation, description, and
classification of hazardous material.
(B) The packing, repacking, handling,
labeling, marking, and placarding of
hazardous material.
(C) The preparation, execution, and use of
shipping documents related to hazardous
material and requirements related to the
number, contents, and placement of those
documents.
(D) The written notification, recording, and
reporting of the unintentional release in
transportation of hazardous material.
(E) The designing, manufacturing,
fabricating, inspecting, marking, maintaining,
reconditioning, repairing, or testing a
package, container, or packaging component
that is represented, marked, certified, or sold
as qualified for use in transporting hazardous
material.
The Supreme Court has found ‘‘that
common-law causes of action for
negligence and strict liability do impose
‘requirement[s]’ ’’ that may be subject to
preemption by Federal laws. Riegel v.
Medtronic, 552 U.S. 312, 323, 128 S.Ct.
999, 1007 (2008). The Supreme Court
has also specifically recognized the
authority in 49 U.S.C. 5125 for DOT ‘‘to
decide whether a state or local statute
that conflicts with the regulation of
hazardous [materials] transportation is
pre-empted.’’ Wyeth v. Levine, 555 U.S.
555, 129 S.Ct. 1187, 1201 n.9 (2009).
Under 49 U.S.C. 5125(d)(1), any
person (including a State, political
subdivision of a State, or Indian tribe)
directly affected by a requirement of a
State, political subdivision or tribe may
apply to the Secretary of Transportation
for a determination whether the
requirement is preempted. The
Secretary of Transportation has
delegated authority to PHMSA to make
determinations of preemption, except
for those concerning highway routing
(which have been delegated to the
Federal Motor Carrier Safety
Administration). 49 CFR 1.53(b).
7 To be ‘‘substantively the same,’’ the non-Federal
requirement must conform ‘‘in every significant
respect to the Federal requirement. Editorial and
other similar de minimis changes are permitted.’’ 49
CFR 107.202(d). Additional standards apply to
preemption of non-Federal requirements on
highway routes over which hazardous materials
may or may not be transported and fees related to
transporting hazardous material. See 49 U.S.C.
5125(c) and (f).
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Section 5125(d)(1) requires notice of
an application for a preemption
determination to be published in the
Federal Register. Following the receipt
and consideration of written comments,
PHMSA publishes its determination in
the Federal Register. See 49 CFR
107.209(c).
Preemption determinations do not
address issues of preemption arising
under the Commerce Clause, the Fifth
Amendment or other provisions of the
Constitution, or statutes other than the
Federal hazardous material
transportation law unless it is necessary
to do so in order to determine whether
a requirement is authorized by another
Federal law, or whether a fee is ‘‘fair’’
within the meaning of 49 U.S.C.
5125(f)(1). A State, local or Indian tribe
requirement is not authorized by
another Federal law merely because it is
not preempted by another Federal
statute. Colorado Pub. Util. Comm’n v.
Harmon, above, 951 F.2d at 1581 n.10.
In making preemption determinations
under 49 U.S.C. 5125(d), PHMSA is
guided by the principles and policies set
forth in Executive Order No. 13132,
entitled ‘‘Federalism’’ (64 FR 43255
(Aug. 10, 1999)), and the President’s
May 20, 2009 memorandum on
‘‘Preemption’’ (74 FR 24693 (May 22,
2009)). Section 4(a) of that Executive
Order authorizes preemption of State
laws only when a statute contains an
express preemption provision, there is
other clear evidence Congress intended
to preempt State law, or the exercise of
State authority directly conflicts with
the exercise of Federal authority. The
President’s May 20, 2009 memorandum
sets forth the policy ‘‘that preemption of
State law by executive departments and
agencies should be undertaken only
with full consideration of the legitimate
prerogatives of the States and with a
sufficient legal basis for preemption.’’
Section 5125 contains express
preemption provisions, which PHMSA
has implemented through its regulations
and which PHMSA applies in making
administrative preemption
determinations.
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III. Discussion
A. Summary of Comments
AMTROL asserts that the Elders’
common law tort claims are preempted
because they could create design,
manufacturing, and marking and
labeling requirements for DOT
specification cylinders that are not
substantively the same as the
requirements in 49 CFR 178.65. In its
original application, it stated that
‘‘[a]pplication of the state court
requirement would undercut’’ the ‘‘need
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for national uniformity’’ in requirements
for the packaging of hazardous
materials, as discussed in PHMSA’s
determinations in Inconsistency Rulings
Nos. 7–15, 49 FR 36632, 36633 (Nov. 22,
1984). AMTROL also stated that, ‘‘as
presented by the [Elders’] common law
claims, the only issue has to do with
requirements for labeling and design of
a specification 39 cylinder’’ which ‘‘are
not ‘substantively the same’ as the
requirements’’ in the HMR and,
‘‘[c]onsequently, such ‘requirements’ are
preempted.’’
The Elders frame the issue in terms of
whether the design, manufacturing, and
marking requirements for a DOT
specification 39 cylinder apply to a
cylinder that was being ‘‘used.’’ The
Elders acknowledge ‘‘that the cylinder
in question, as designed and
manufactured, complies with all of the
specifications set forth in 49 CFR 178.65
* * * and complies with all the labels
and warnings required by the DOT
specification.’’ However, they assert that
‘‘warnings should be utilized to protect
the end user,’’ because ‘‘the
manufacturer knew or should have
known that the cylinders could rust.’’ 8
The Elders stated that the technician
was not using the cylinder in a
transportation mode; he was simply
using the cylinder as an end-user on the
job after its journey had ended.’’
Accordingly, they assert that ‘‘a State
common law requirement that the
products being used on the job be safe
for their intended use does not interfere
with the DOT regulation. The state
common law does not seek to impose its
requirement where the cylinder in
question clearly, at the time of its
manufacture and transportation,
complied with the DOT
specifications.’’ 9
Mr. Wilson stated that ‘‘the common
law tort claim appears to be about
design and labeling of the compressed
gas cylinder as it relates to consumer
use—not as it relates to use of the
cylinder in transporting hazardous
materials in commerce.’’ However, he
also noted ‘‘that end-users may retransport hazmat during their daily
8 The Elders provided three samples of ‘‘warnings
utilized in the past by manufacturers [that] state:
‘Overheating, pressurizing, or rusting can cause
cylinder to burst, resulting in serious personal
injury or death.’ ’’
9 The Elders also cited and quoted from cases
which they contend ‘‘are applicable’’ or ‘‘nearly on
all fours with the present case.’’ However, some of
these cases appear to have involved an injury from
a hazardous material that was not packaged or
handled in complete compliance with requirements
in the HMR. In other cases, the hazardous material
was a consumer item purchased for personal use
and subject to regulations of the Consumer Product
Safety Commission.
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39569
routine,’’ acknowledging implicitly that
the HMR applied to Mr. Elder’s
transportation of the cylinder from his
shop to his customer’s location.
According to GAWDA, the critical
inquiry is ‘‘whether Congress intended
to preempt certain specific types of
claims,’’ and an ‘‘[a]nalysis of this
question must begin, as the Supreme
Court has stated, with determining
Congressional intent’’ (citing Altria
Group, Inc. v. Good, 129 S.Ct. 398, 543
(2008)). It rejected the Elders’ position
that State requirements covering ‘‘end
use’’ are not preempted by 49 U.S.C.
5125 and stated:
Clearly, it is immaterial whether the
cylinder in question was at its final
destination or how long it had been there, if
it was marked indicating it was a DOT–39
cylinder; it was by definition subject to DOT
regulation. Therefore, any state requirements
of additional manufacturing specifications or
packaging warnings must affect the
‘‘transportation’’ of the cylinder and are,
therefore, preempted by HMTA.
B. Analysis
Federal hazardous material
transportation law explicitly provides
that the HMR apply to the design,
manufacture, and marking of packagings
(such as cylinders) that are
‘‘represented, marked, certified, or sold
as qualified for use in transporting
hazardous material in commerce.’’ 49
U.S.C. 5103(b)(1)(A)(iii), (b)(1)(E). In its
October 30, 2003 final rule, on the
‘‘Applicability of the Hazardous
Materials Regulations to Loading,
Unloading, and Storage,’’ PHMSA
explained that ‘‘[p]ackaging integrity is
critical to safe transportation of
hazardous materials, and
uniformity of packaging requirements assures
the safe and efficient movement of hazardous
materials across state lines and international
boundaries. Thus, consistent with the
preemption provisions of Federal hazmat
law, the Secretary’s regulatory jurisdiction in
this area must preempt state and local law.
68 FR 61906, 61908. PHMSA continued
by explaining that ‘‘because a packaging
that is used for storage one day may be
used for transportation the next, it is
critical to transportation safety that
packagings represented as meeting DOT
or UN specifications in fact do so.’’ Id.
Accordingly, ‘‘[i]f a packaging shows
evidence that its effectiveness as a
container may be substantially reduced
or if the packaging has been subjected
to conditions or operating practices that
could reduce its effectiveness, it must be
inspected and repaired, in accordance
with applicable requirements, before it
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can be filled and offered for
transportation. Id.10
In this final rule, PHMSA relocated to
49 CFR 171.2(g) and revised without
making any substantive change to the
wording of former § 171.2(c) (Oct. 1,
2003 ed.) to read:
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No person may represent, mark, certify,
sell, or offer a packaging or container as
meeting the requirements of this subchapter
governing its use in the transportation of a
hazardous material in commerce unless the
packaging or container is manufactured,
fabricated, marked, maintained,
reconditioned, repaired, and retested in
accordance with the applicable requirements
of this subchapter * * * The requirements of
this paragraph apply whether or not the
packaging or container is used or to be used
for the transportation of a hazardous
material.
These provisions in the HMR and the
‘‘substantively the same as’’ preemption
standard added to the law in 1990 carry
out the finding of the House of
Representatives Committee on Energy
and Commerce that there is ‘‘a
compelling need for standardized
requirements relating to certain areas of
the transportation of hazardous
materials. Conflicting Federal, State and
local requirements pose potentially
serious threats to the safe transportation
of hazardous materials.’’ H. Rept. 101–
444, part 1, pp 33–34 (Apr. 3, 1990). In
particular, ‘‘[u]niform requirements for
designing, manufacturing, and testing
such containers and packages will
enhance the safe transportation of
hazardous materials by allowing for ease
of identification, familiarity with
characteristics of packages and
containers and consistency in systems
designed to handle such hazardous
materials.’’ Id. at 35.
It is not necessary to determine
whether the DOT specification 39
cylinder was in ‘‘transportation’’ when
it failed, because the HMR applied to
AMTROL when it designed,
manufactured, and marked the cylinder
‘‘as qualified for use in transporting
hazardous material in commerce.’’ 49
U.S.C. 5103(b)(1)(A)(iii). The Elders’
contention that the design, manufacture,
and marking requirements in 49 CFR
178.65 do not ‘‘cover [Mr. Elder’s] use
of the cylinder’’ is beside the point, as
is its position that the ‘‘use’’ to which
the cylinder might be put is ‘‘outside the
purview’’ of that section of the HMR.
Rather, the ‘‘substantively the same as’’
preemption provision in 49 U.S.C.
10 See, e.g., 49 CFR 173.301(a)(2): ‘‘A cylinder that
has a crack or leak, is bulged, has a defective valve
or a leaking or defective pressure relief device, or
bears evidence of physical abuse, fire or heat
damage, or detrimental rusting or corrosion, may
not be filled and offered for transportation.’’
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5125(b)(1)(E) must govern the
‘‘adequacy of the cylinder’’ at all times
that it is ‘‘represented, marked, certified,
or sold as qualified for use in
transporting hazardous material in
commerce,’’ and not just the period in
time ‘‘when it was used to transport
hazardous material,’’ as the Elders
contend.
The U.S. Court of Appeals for the
Third Circuit reached the same
conclusion in Roth v. Norfalco LLC, 651
F.3d 367, 379–80 (2011). In this case,
the Court affirmed a summary judgment
in favor of the manufacturer of a rail
tank car from which sulfuric acid had
sprayed when the tank car was being
unloaded by an employee of the
consignee of the shipment and stated:
Here, the statute and its applicability could
not be more clear. Roth seeks to impose a
tank car design requirement. Section
5125(b)(1) expressly preempts any common
law requirement ‘‘about’’ the design of a
‘‘package, container, or packaging component
* * * qualified for use in transporting
hazardous materials in commerce.’’ * * * It
is irrelevant what Roth was doing at the
precise moment of his injury * * * The tank
car is, at all times, a container qualified for
use in transporting hazardous materials. The
proposed design requirement is expressly
preempted.
It should be noted that the
preemption provision in 49 U.S.C.
5125(b)(1)(E) would not insulate a
person who improperly, and in
violation of the HMR, offers or
transports a hazardous material in a
packaging ‘‘that is represented, marked,
certified, or sold as qualified for use in
transporting hazardous material in
commerce.’’ Nor would there be
preemption of a common law tort action
for damages when the packaging does
not, in fact, meet the applicable design
and manufacturing specification in the
HMR.11
Under the plain language of the
Federal hazardous material
transportation law, requirements in the
HMR govern the design, manufacture,
and marking of ‘‘a package, container, or
packaging component that is
represented, marked, certified, or sold
as qualified for use in transporting
hazardous material in commerce.’’ 49
U.S.C. 5103(b)(1)(A)(iii), 49 CFR
171.1(a). Any State requirement,
including a State’s common law, on the
‘‘designing, manufacturing, [or] marking
* * * a package, container, or
packaging component that is
11 Moreover, the Consumer Product Safety
Commission (CPSC) has the authority to require
‘‘that a consumer product be marked with or
accompanied by clear and adequate warnings or
instructions, or requirements respecting the form of
warnings or instructions.’’ 15 U.S.C. 2056(a).
PO 00000
Frm 00108
Fmt 4703
Sfmt 4703
represented, marked, certified, or sold
as qualified for use in transporting
hazardous material in commerce’’ is
preempted unless it is ‘‘substantively
the same as’’ the requirements in the
HMR. 49 U.S.C. 5125(b)(1)(E). The
Elders have not pointed to, and PHMSA
is not aware of, any other Federal law
that would authorize the common law
tort claims asserted by the Elders that
the manufacturer of a DOT specification
39 compressed gas cylinder should have
designed the cylinder (or any
component thereof) in a different
manner than—or marked or labeled the
cylinder with any information beyond
that required by—49 CFR 178.65.
IV. Ruling
Federal hazardous material
transportation law preempts a private
cause of action which seeks to create or
establish a State common law
requirement applicable to the design,
manufacture, or marking of a packaging,
container, or packaging component that
is represented, marked, certified, or sold
as qualified for use in transporting
hazardous material in commerce when
that State common law requirement
would not be substantively the same as
the requirements in the HMR. Federal
hazardous material transportation law
does not preempt tort claims that the
packaging or packaging component
failed to meet the design,
manufacturing, or marking requirements
in the HMR or that a person who offered
a hazardous material for transportation
in commerce or transported a hazardous
material in commerce failed to comply
with applicable requirements in the
HMR.
V. Petition for Reconsideration/Judicial
Review
In accordance with 49 CFR
107.211(a), any person aggrieved by this
decision may file a petition for
reconsideration within 20 days of
publication of this decision in the
Federal Register. A petition for judicial
review of a final preemption
determination must be filed in the
United States Court of Appeals for the
District of Columbia or in the Court of
Appeals for the United States for the
circuit in which the petitioner resides or
has its principal place of business,
within 60 days after the determination
becomes final. 49 U.S.C. 5127(a).
This decision will become PHMSA’s
final decision 20 days after publication
in the Federal Register if no petition for
reconsideration is filed within that time.
The filing of a petition for
reconsideration is not a prerequisite to
seeking judicial review of this decision
under 49 U.S.C. 5127(a).
E:\FR\FM\03JYN1.SGM
03JYN1
Federal Register / Vol. 77, No. 128 / Tuesday, July 3, 2012 / Notices
If a petition for reconsideration is
filed within 20 days of publication in
the Federal Register, the action by
PHMSA’s Chief Counsel on the petition
for reconsideration will be PHMSA’s
final action. 49 CFR 107.211(d).
Issued in Washington, DC, on June 26,
2012.
Vanessa L. Allen Sutherland,
Chief Counsel.
[FR Doc. 2012–16240 Filed 7–2–12; 8:45 am]
BILLING CODE 4910–60–P
DEPARTMENT OF TRANSPORTATION
Surface Transportation Board
[Docket No. MCF 21047]1
Frank Sherman, FSCS Corporation,
TMS West Coast, Inc.,
Evergreen Trails, Inc. and Cabana
Coaches, LLC—Acquisition and
Consolidation of Assets—America
Charters, LTD., American Coach Lines
of Jacksonville, Inc., American Coach
Lines of Miami, Inc., American Coach
Lines of Orlando, Inc., CUSA ASL, LLC,
CUSA BCCAE, LLC, CUSA CC, LLC,
CUSA FL, LLC, CUSA GCBS, LLC,
CUSA GCT, LLC, CUSA K–TCS, LLC,
and Midnight Sun Tours, Inc.
AGENCY: Surface Transportation Board,
DOT.
ACTION: Notice of Finance Application.
On June 4, 2012, Frank
Sherman, an individual who controls
motor passenger carriers, together with
FSCS Corporation, a noncarrier holding
company; TMS West Coast, Inc., a
noncarrier holding company; Evergreen
Trails, Inc. d/b/a Horizon Coach Lines
(Evergreen), an interstate motor
passenger carrier; and Cabana Coaches,
LLC (Cabana), an interstate motor
passenger carrier (collectively,
Applicants) filed an application for
approval under 49 U.S.C. 14303 to
acquire the assets of 12 separate
interstate motor passenger common
carrier subsidiaries of noncarrier Coach
America Holdings, Inc. (Coach
America)—American Charters, Ltd.
(Charters); American Coach Lines of
Jacksonville, Inc. (Coach-Jacksonville);
American Coach Lines of Miami, Inc.
(Coach-Miami); American Coach Lines
of Orlando, Inc. (Coach-Orlando); CUSA
ASL, LLC; CUSA BCCAE, LLC; CUSA
CC, LLC; CUSA FL, LLC; CUSA GCBS,
LLC; CUSA GCT, LLC; CUSA K–TCS,
srobinson on DSK4SPTVN1PROD with NOTICES
SUMMARY:
1 A request for interim approval under 49 U.S.C.
14303(i) and 49 CFR 1182.7 was included in this
filing (Docket No. MCF 21047 TA). In a decision
served on June 29, 2012, interim approval was
granted, effective on the service date of the
decision.
VerDate Mar<15>2010
16:27 Jul 02, 2012
Jkt 226001
LLC; and Midnight Sun Tours, Inc.
(Midnight Sun) (collectively, Coach
America Subsidiaries)—and to
consolidate certain of those assets into
Evergreen and others into Cabana.
Specifically, the transaction
contemplates that: (1) the assets of
Charters; Coach-Jacksonville; CoachOrlando; CUSA ASL, LLC; CUSA
BCCAE, LLC; CUSA CC, LLC; CUSA FL,
LLC; CUSA GCBS, LLC; CUSA GCT,
LLC; and CUSA K–TCS, LLC, would be
purchased by either FSCS or Evergreen
to be operated under the Horizon Coach
Lines name; and (2) the assets of CoachMiami and Midnight Sun would be
purchased by either FSCS or Cabana
and consolidated into Cabana. Cabana
would also adopt the d/b/a name
‘‘Horizon Coach Lines,’’ and the assets
consolidated into Cabana would be
operated under that name. Under an
asset purchase agreement that was
entered into on May 18, 2012, see infra,
another company controlled by
Sherman, Transportation Management
Services, Inc. (TMS), obtained the right
to purchase the Coach America
Subsidiaries. TMS is to assign its right
to purchase to either FSCS or to
Evergreen and Cabana. If TMS assigns
its right to purchase to Evergreen and
Cabana, Cabana will receive the right to
purchase the assets of Coach-Miami and
Midnight Sun and Evergreen will
receive the right to purchase the assets
of all of the other Coach America
Subsidiaries identified above.
On June 6, 2012, Michael Yusim, an
individual, filed a letter in opposition to
the proposed transaction, asserting that
the public interest would not be served
by allowing the transaction to proceed
until two cases before the Secretary of
Labor (Secretary) are completed. On
June 19, 2012, the Ventura County
Transportation Commission (VCTC), a
California public agency that operates a
regional bus system with connections to
municipal and local transit operators,
filed a request for delay of the proposed
acquisition of assets or for conditions.
Copies of this notice will be served on
Mr. Yusim and VCTC. Persons wishing
to oppose the application must follow
the rules set forth at 49 CFR 1182.5 and
1182.8.
DATES: Comments must be filed by
August 17, 2012. Applicants may file a
reply by September 4, 2012.
ADDRESSES: Send an original and 10
copies of any comments referring to
Docket No. MCF 21047 to: Surface
Transportation Board, 395 E Street SW.,
Washington, DC 20423–0001. In
addition, send one copy of comments to
Applicants’ representative: David H.
Coburn, Steptoe & Johnson LLP, 1330
PO 00000
Frm 00109
Fmt 4703
Sfmt 4703
39571
Connecticut Avenue NW., Washington,
DC 20036.
FOR FURTHER INFORMATION CONTACT:
Marc Lerner, (202) 245–0390. [Federal
Information Relay Service (FIRS) for the
hearing impaired: 1–800–877–8339.]
SUPPLEMENTARY INFORMATION: The Coach
America Subsidiaries are currently
involved in proceedings instituted
under Chapter 11 of the Bankruptcy
Code, having filed a voluntary petition
for relief with the U.S. Bankruptcy
Court for the District of Delaware on
January 3, 2012. On January 13, 2012,
the Coach America Subsidiaries also
filed a motion to sell substantially all of
their assets and effectively to liquidate.
According to Applicants, the proposed
acquisition is evidenced by an Asset
Purchase Agreement that was entered
into by the parties on May 18, 2012, and
was approved by the bankruptcy court
at a hearing on May 22, 2012.
On June 6, 2012, Mr. Yusim filed a
letter in opposition to both the request
for interim approval and the application
for permanent authority. Applicants
filed a reply to Mr. Yusim’s letter on
June 11, 2012, and Mr. Yusim
responded on June 12, 2012. The basis
for Mr. Yusim’s opposition relates to
two cases alleging that Midnight Sun
discriminated against him and another
driver, both employed by Midnight Sun,
for having accurately reported their
hours of service. According to Mr.
Yusim, the two cases are pending before
the Secretary, but have been stayed by
the bankruptcy court. Mr. Yusim
requests that the Board disallow the sale
of any subsidiaries of Coach America
until the Secretary is allowed to hear the
two cases.
On June 19, 2012, the Ventura County
Transportation Commission (VCTC), a
California public agency that operates a
regional bus, filed a pleading stating
that CUSA CC, LLC, is in violation of its
operating agreement with VCTC because
it has given insufficient notice of its
intent to terminate the services it
provides for VCTC and its riders, and
that the communications VCTC has had
with CUSA CC, LLC and TMS have led
only to a possibility that these services
could continue through July 2012.
VCTC requests either that the proposed
acquisition of assets be delayed or that
conditions be placed on the transaction
to assure both adequate time to find a
new contractor to provide these
‘‘essential’’ services and a surviving
entity to charge with breach of contract.
We have, by separate decision,
granted Applicants interim approval to
acquire management and operational
control of the assets under 49 U.S.C.
14303(i) and the Board’s regulations at
E:\FR\FM\03JYN1.SGM
03JYN1
Agencies
[Federal Register Volume 77, Number 128 (Tuesday, July 3, 2012)]
[Notices]
[Pages 39567-39571]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-16240]
-----------------------------------------------------------------------
DEPARTMENT OF TRANSPORTATION
Pipeline and Hazardous Materials Safety Administration
[Docket No. PHMSA-2009-0017 (PD-34(R))]
Common Law Tort Claims Concerning Design and Marking of DOT
Specification 39 Compressed Gas Cylinders
AGENCY: Pipeline and Hazardous Materials Safety Administration (PHMSA),
DOT.
ACTION: Notice of administrative determination of preemption.
-----------------------------------------------------------------------
Applicable Federal Requirements: Federal hazardous material
transportation law, 49 U.S.C. 5101 et seq., and the Hazardous Materials
Regulations (HMR), 49 CFR parts 171-180.
Modes Affected: All transportation modes.
SUMMARY: Federal hazardous material transportation law preempts a
private cause of action which seeks to create or establish a State
common law requirement applicable to the design, manufacture, or
marking of a packaging, container, or packaging component that is
represented, marked, certified, or sold as qualified for use in
transporting hazardous material in commerce when that State common law
requirement would not be substantively the same as the requirements in
the HMR. Federal hazardous material transportation law does not preempt
a tort claim that a packaging, container, or packaging component that
is represented, marked, certified, or sold as qualified for use in
transporting hazardous material failed to meet the design,
manufacturing, or marking requirements in the HMR or that a person who
offered a hazardous material for transportation in commerce or
transported a hazardous material in commerce failed to comply with
applicable requirements in the HMR.
FOR FURTHER INFORMATION CONTACT: Frazer C. Hilder, Office of Chief
Counsel, Pipeline and Hazardous Materials Safety Administration, U.S.
Department of Transportation, 1200 New Jersey Avenue SE., Washington,
DC 20590-0001 (Tel. No. 202-366-4400).
SUPPLEMENTARY INFORMATION:
I. Application
AMTROL, Inc. has applied to PHMSA for an administrative
determination whether the Federal hazardous
[[Page 39568]]
materials transportation law \1\ preempts State common law tort claims
that the manufacturer of a DOT specification 39 compressed gas cylinder
should have designed the cylinder to resist rusting and/or marked or
labeled the cylinder with warnings of the potential hazard of rusting
over time.
---------------------------------------------------------------------------
\1\ The Federal hazardous material transportation law currently
codified at 49 U.S.C. 5101 et seq. is often referred to by the
acronym ``HMTA'' for the Hazardous Materials Transportation Act,
Public Law 93-633, 88 Stat. 2156, enacted January 3, 1975. Prior to
codification in 1994 (Pub. L. 103-272, 108 Stat. 745 (July 5,
1994)), the HMTA was set forth at 49 App. U.S.C.A. 1801 et seq.
---------------------------------------------------------------------------
A DOT specification 39 cylinder is a non-reusable (non-refillable)
seamless, welded, or brazed cylinder made of steel or aluminum (having
certain specified characteristics), with size limitations (depending on
the service pressure of the cylinder) and requirements for
manufacturing, minimum thickness of the cylinder wall, openings and
attachments on the head of the cylinder, and pressure and flattening
testing. 49 CFR 178.65. Subsection 178.65(i) provides that the cylinder
must be marked with certain information \2\ including the specification
number, service and test pressure, date of manufacture and a
registration number identifying the manufacturer, and:
---------------------------------------------------------------------------
\2\ In this determination, the word ``marking'' is used to refer
to the information required to be marked on a DOT specification 39
cylinder under 49 CFR 178.65(i)--to distinguish this marking from a
hazard class warning label (e.g., NONFLAMMABLE GAS) and a product
sticker or label that may contain the proper shipping name and UN
identification number required to be marked on the filled cylinder
by a person who offers the filled cylinder for transportation in
commerce. See 49 CFR 172.301 et seq. and 172.400 et seq.
--``NRC'' for ``non-reusable container,'' and
--the statement that ``Federal law forbids transportation if
refilled'' plus a statement of the maximum civil and criminal
penalties applicable at the date of manufacture.
On January 30, 2009, PHMSA published a notice in the Federal
Register inviting interested persons to comment on AMTROL's
application. 74 FR 5723. As discussed in this notice, a products
liability lawsuit had been brought against AMTROL and other defendants
by the survivors and next of kin of Kenneth Elder (the ``Elders'') who
died on January 24, 2003, when a rusted DOT specification 39 cylinder
ruptured after Mr. Elder placed the cylinder in 179 degree water.\3\
---------------------------------------------------------------------------
\3\ The Elders' claims against AMTROL are presently pending as a
claim in bankruptcy in the U.S. Court of Appeals for the Third
Circuit which has issued a stay pending PHMSA's determination. In re
Amtrol Holdings, Inc. v. Kenneth Elder, No. 10-3273.
---------------------------------------------------------------------------
In response to AMTROL's application and the January 30, 2009
Federal Register notice, comments were submitted by AMTROL, the Elders,
Thomas Wilson (a retired hazmat shipper who occasionally acts as a
consultant), and the Gases and Welding Distributors Association, Inc.
(GAWDA).\4\
---------------------------------------------------------------------------
\4\ GAWDA describes itself as ``a national trade association
representing the interests of some 600 distributors of compressed
and cryogenic gases and related supplies and equipment in the United
States and Canada,'' some of which ``fill, store, handle and
transport gases in DOT-39 compressed gas cylinders.''
---------------------------------------------------------------------------
II. Federal Preemption
A United States Court of Appeals has found that uniformity was the
``linchpin'' in the design of the Federal laws governing the
transportation of hazardous materials. Colorado Pub. Util. Comm'n v.
Harmon, 951 F.2d 1571, 1575 (10th Cir. 1991). Section 5125 of Title 49
U.S.C. contains express preemption provisions. As amended by Section
1711(b) of the Homeland Security Act of 2002 (Pub. L. 107-296, 116
Stat. 2320),\5\ Sec. 5125(a) provides that a requirement of a State,
political subdivision of a State, or Indian tribe is preempted--unless
the non-Federal requirement is authorized by another Federal law or DOT
grants a waiver of preemption under Sec. 5125(e)--if
---------------------------------------------------------------------------
\5\ Section 1711 of the Homeland Security Act of 2002 added the
words ``including security'' to the applicability provisions in 49
U.S.C. 5103(b)(1) and the preemption provisions in Sec. 5125(a) and
(b)(1). Otherwise, the 1994 codification of Title 49 and subsequent
editorial revisions and technical corrections have not made any
substantive changes to these provisions since amendment of the
original HMTA in 1990. See Sec. 7122(a) of the Hazardous Materials
Transportation Safety and Security Reauthorization Act of 2005,
which is Title VII of the Safe, Accountable, Flexible, Efficient
Transportation Equity Act: A Legacy for Users (SAFETEA-LU), Pub. L.
109-59, 119 Stat. 1891 (Aug. 10, 2005), and Public Law 110-244 Sec.
302(b), 122 Stat. 1618 (June 6, 2008).
(1) Complying with a requirement of the State, political
subdivision, or tribe and a requirement of this chapter, a
regulation prescribed under this chapter, or a hazardous materials
transportation security regulation or directive issued by the
Secretary of Homeland Security is not possible; or
(2) The requirement of the State, political subdivision, or
tribe, as applied or enforced, is an obstacle to accomplishing and
carrying out this chapter, a regulation prescribed under this
chapter, or a hazardous materials transportation security regulation
or directive issued by the Secretary of Homeland Security.\6\
---------------------------------------------------------------------------
\6\ These two paragraphs set forth the ``dual compliance'' and
``obstacle'' criteria which are based on U.S. Supreme Court
decisions on preemption. Hines v. Davidowitz, 312 U.S. 52 (1941);
Florida Lime & Avocado Growers, Inc. v. Paul, 373 U.S. 132 (1963);
Ray v. Atlantic Richfield, Inc., 435 U.S. 151 (1978).
Subsection (b)(1) of 49 U.S.C. 5125 further provides that a non-
Federal requirement concerning any of the following subjects is
preempted--unless authorized by another Federal law or DOT grants a
waiver of preemption--when the non-Federal requirement is not
``substantively the same as'' a provision of Federal hazardous material
transportation law, a regulation prescribed under that law, or a
hazardous materials security regulation or directive issued by the
Department of Homeland Security: \7\
---------------------------------------------------------------------------
\7\ To be ``substantively the same,'' the non-Federal
requirement must conform ``in every significant respect to the
Federal requirement. Editorial and other similar de minimis changes
are permitted.'' 49 CFR 107.202(d). Additional standards apply to
preemption of non-Federal requirements on highway routes over which
hazardous materials may or may not be transported and fees related
to transporting hazardous material. See 49 U.S.C. 5125(c) and (f).
(A) The designation, description, and classification of
hazardous material.
(B) The packing, repacking, handling, labeling, marking, and
placarding of hazardous material.
(C) The preparation, execution, and use of shipping documents
related to hazardous material and requirements related to the
number, contents, and placement of those documents.
(D) The written notification, recording, and reporting of the
unintentional release in transportation of hazardous material.
(E) The designing, manufacturing, fabricating, inspecting,
marking, maintaining, reconditioning, repairing, or testing a
package, container, or packaging component that is represented,
marked, certified, or sold as qualified for use in transporting
hazardous material.
The Supreme Court has found ``that common-law causes of action for
negligence and strict liability do impose `requirement[s]' '' that may
be subject to preemption by Federal laws. Riegel v. Medtronic, 552 U.S.
312, 323, 128 S.Ct. 999, 1007 (2008). The Supreme Court has also
specifically recognized the authority in 49 U.S.C. 5125 for DOT ``to
decide whether a state or local statute that conflicts with the
regulation of hazardous [materials] transportation is pre-empted.''
Wyeth v. Levine, 555 U.S. 555, 129 S.Ct. 1187, 1201 n.9 (2009).
Under 49 U.S.C. 5125(d)(1), any person (including a State,
political subdivision of a State, or Indian tribe) directly affected by
a requirement of a State, political subdivision or tribe may apply to
the Secretary of Transportation for a determination whether the
requirement is preempted. The Secretary of Transportation has delegated
authority to PHMSA to make determinations of preemption, except for
those concerning highway routing (which have been delegated to the
Federal Motor Carrier Safety Administration). 49 CFR 1.53(b).
[[Page 39569]]
Section 5125(d)(1) requires notice of an application for a
preemption determination to be published in the Federal Register.
Following the receipt and consideration of written comments, PHMSA
publishes its determination in the Federal Register. See 49 CFR
107.209(c).
Preemption determinations do not address issues of preemption
arising under the Commerce Clause, the Fifth Amendment or other
provisions of the Constitution, or statutes other than the Federal
hazardous material transportation law unless it is necessary to do so
in order to determine whether a requirement is authorized by another
Federal law, or whether a fee is ``fair'' within the meaning of 49
U.S.C. 5125(f)(1). A State, local or Indian tribe requirement is not
authorized by another Federal law merely because it is not preempted by
another Federal statute. Colorado Pub. Util. Comm'n v. Harmon, above,
951 F.2d at 1581 n.10.
In making preemption determinations under 49 U.S.C. 5125(d), PHMSA
is guided by the principles and policies set forth in Executive Order
No. 13132, entitled ``Federalism'' (64 FR 43255 (Aug. 10, 1999)), and
the President's May 20, 2009 memorandum on ``Preemption'' (74 FR 24693
(May 22, 2009)). Section 4(a) of that Executive Order authorizes
preemption of State laws only when a statute contains an express
preemption provision, there is other clear evidence Congress intended
to preempt State law, or the exercise of State authority directly
conflicts with the exercise of Federal authority. The President's May
20, 2009 memorandum sets forth the policy ``that preemption of State
law by executive departments and agencies should be undertaken only
with full consideration of the legitimate prerogatives of the States
and with a sufficient legal basis for preemption.'' Section 5125
contains express preemption provisions, which PHMSA has implemented
through its regulations and which PHMSA applies in making
administrative preemption determinations.
III. Discussion
A. Summary of Comments
AMTROL asserts that the Elders' common law tort claims are
preempted because they could create design, manufacturing, and marking
and labeling requirements for DOT specification cylinders that are not
substantively the same as the requirements in 49 CFR 178.65. In its
original application, it stated that ``[a]pplication of the state court
requirement would undercut'' the ``need for national uniformity'' in
requirements for the packaging of hazardous materials, as discussed in
PHMSA's determinations in Inconsistency Rulings Nos. 7-15, 49 FR 36632,
36633 (Nov. 22, 1984). AMTROL also stated that, ``as presented by the
[Elders'] common law claims, the only issue has to do with requirements
for labeling and design of a specification 39 cylinder'' which ``are
not `substantively the same' as the requirements'' in the HMR and,
``[c]onsequently, such `requirements' are preempted.''
The Elders frame the issue in terms of whether the design,
manufacturing, and marking requirements for a DOT specification 39
cylinder apply to a cylinder that was being ``used.'' The Elders
acknowledge ``that the cylinder in question, as designed and
manufactured, complies with all of the specifications set forth in 49
CFR 178.65 * * * and complies with all the labels and warnings required
by the DOT specification.'' However, they assert that ``warnings should
be utilized to protect the end user,'' because ``the manufacturer knew
or should have known that the cylinders could rust.'' \8\
---------------------------------------------------------------------------
\8\ The Elders provided three samples of ``warnings utilized in
the past by manufacturers [that] state: `Overheating, pressurizing,
or rusting can cause cylinder to burst, resulting in serious
personal injury or death.' ''
---------------------------------------------------------------------------
The Elders stated that the technician was not using the cylinder in
a transportation mode; he was simply using the cylinder as an end-user
on the job after its journey had ended.'' Accordingly, they assert that
``a State common law requirement that the products being used on the
job be safe for their intended use does not interfere with the DOT
regulation. The state common law does not seek to impose its
requirement where the cylinder in question clearly, at the time of its
manufacture and transportation, complied with the DOT specifications.''
\9\
---------------------------------------------------------------------------
\9\ The Elders also cited and quoted from cases which they
contend ``are applicable'' or ``nearly on all fours with the present
case.'' However, some of these cases appear to have involved an
injury from a hazardous material that was not packaged or handled in
complete compliance with requirements in the HMR. In other cases,
the hazardous material was a consumer item purchased for personal
use and subject to regulations of the Consumer Product Safety
Commission.
---------------------------------------------------------------------------
Mr. Wilson stated that ``the common law tort claim appears to be
about design and labeling of the compressed gas cylinder as it relates
to consumer use--not as it relates to use of the cylinder in
transporting hazardous materials in commerce.'' However, he also noted
``that end-users may re-transport hazmat during their daily routine,''
acknowledging implicitly that the HMR applied to Mr. Elder's
transportation of the cylinder from his shop to his customer's
location.
According to GAWDA, the critical inquiry is ``whether Congress
intended to preempt certain specific types of claims,'' and an
``[a]nalysis of this question must begin, as the Supreme Court has
stated, with determining Congressional intent'' (citing Altria Group,
Inc. v. Good, 129 S.Ct. 398, 543 (2008)). It rejected the Elders'
position that State requirements covering ``end use'' are not preempted
by 49 U.S.C. 5125 and stated:
Clearly, it is immaterial whether the cylinder in question was
at its final destination or how long it had been there, if it was
marked indicating it was a DOT-39 cylinder; it was by definition
subject to DOT regulation. Therefore, any state requirements of
additional manufacturing specifications or packaging warnings must
affect the ``transportation'' of the cylinder and are, therefore,
preempted by HMTA.
B. Analysis
Federal hazardous material transportation law explicitly provides
that the HMR apply to the design, manufacture, and marking of
packagings (such as cylinders) that are ``represented, marked,
certified, or sold as qualified for use in transporting hazardous
material in commerce.'' 49 U.S.C. 5103(b)(1)(A)(iii), (b)(1)(E). In its
October 30, 2003 final rule, on the ``Applicability of the Hazardous
Materials Regulations to Loading, Unloading, and Storage,'' PHMSA
explained that ``[p]ackaging integrity is critical to safe
transportation of hazardous materials, and
uniformity of packaging requirements assures the safe and efficient
movement of hazardous materials across state lines and international
boundaries. Thus, consistent with the preemption provisions of
Federal hazmat law, the Secretary's regulatory jurisdiction in this
area must preempt state and local law.
68 FR 61906, 61908. PHMSA continued by explaining that ``because a
packaging that is used for storage one day may be used for
transportation the next, it is critical to transportation safety that
packagings represented as meeting DOT or UN specifications in fact do
so.'' Id. Accordingly, ``[i]f a packaging shows evidence that its
effectiveness as a container may be substantially reduced or if the
packaging has been subjected to conditions or operating practices that
could reduce its effectiveness, it must be inspected and repaired, in
accordance with applicable requirements, before it
[[Page 39570]]
can be filled and offered for transportation. Id.\10\
---------------------------------------------------------------------------
\10\ See, e.g., 49 CFR 173.301(a)(2): ``A cylinder that has a
crack or leak, is bulged, has a defective valve or a leaking or
defective pressure relief device, or bears evidence of physical
abuse, fire or heat damage, or detrimental rusting or corrosion, may
not be filled and offered for transportation.''
---------------------------------------------------------------------------
In this final rule, PHMSA relocated to 49 CFR 171.2(g) and revised
without making any substantive change to the wording of former Sec.
171.2(c) (Oct. 1, 2003 ed.) to read:
No person may represent, mark, certify, sell, or offer a
packaging or container as meeting the requirements of this
subchapter governing its use in the transportation of a hazardous
material in commerce unless the packaging or container is
manufactured, fabricated, marked, maintained, reconditioned,
repaired, and retested in accordance with the applicable
requirements of this subchapter * * * The requirements of this
paragraph apply whether or not the packaging or container is used or
to be used for the transportation of a hazardous material.
These provisions in the HMR and the ``substantively the same as''
preemption standard added to the law in 1990 carry out the finding of
the House of Representatives Committee on Energy and Commerce that
there is ``a compelling need for standardized requirements relating to
certain areas of the transportation of hazardous materials. Conflicting
Federal, State and local requirements pose potentially serious threats
to the safe transportation of hazardous materials.'' H. Rept. 101-444,
part 1, pp 33-34 (Apr. 3, 1990). In particular, ``[u]niform
requirements for designing, manufacturing, and testing such containers
and packages will enhance the safe transportation of hazardous
materials by allowing for ease of identification, familiarity with
characteristics of packages and containers and consistency in systems
designed to handle such hazardous materials.'' Id. at 35.
It is not necessary to determine whether the DOT specification 39
cylinder was in ``transportation'' when it failed, because the HMR
applied to AMTROL when it designed, manufactured, and marked the
cylinder ``as qualified for use in transporting hazardous material in
commerce.'' 49 U.S.C. 5103(b)(1)(A)(iii). The Elders' contention that
the design, manufacture, and marking requirements in 49 CFR 178.65 do
not ``cover [Mr. Elder's] use of the cylinder'' is beside the point, as
is its position that the ``use'' to which the cylinder might be put is
``outside the purview'' of that section of the HMR. Rather, the
``substantively the same as'' preemption provision in 49 U.S.C.
5125(b)(1)(E) must govern the ``adequacy of the cylinder'' at all times
that it is ``represented, marked, certified, or sold as qualified for
use in transporting hazardous material in commerce,'' and not just the
period in time ``when it was used to transport hazardous material,'' as
the Elders contend.
The U.S. Court of Appeals for the Third Circuit reached the same
conclusion in Roth v. Norfalco LLC, 651 F.3d 367, 379-80 (2011). In
this case, the Court affirmed a summary judgment in favor of the
manufacturer of a rail tank car from which sulfuric acid had sprayed
when the tank car was being unloaded by an employee of the consignee of
the shipment and stated:
Here, the statute and its applicability could not be more clear.
Roth seeks to impose a tank car design requirement. Section
5125(b)(1) expressly preempts any common law requirement ``about''
the design of a ``package, container, or packaging component * * *
qualified for use in transporting hazardous materials in commerce.''
* * * It is irrelevant what Roth was doing at the precise moment of
his injury * * * The tank car is, at all times, a container
qualified for use in transporting hazardous materials. The proposed
design requirement is expressly preempted.
It should be noted that the preemption provision in 49 U.S.C.
5125(b)(1)(E) would not insulate a person who improperly, and in
violation of the HMR, offers or transports a hazardous material in a
packaging ``that is represented, marked, certified, or sold as
qualified for use in transporting hazardous material in commerce.'' Nor
would there be preemption of a common law tort action for damages when
the packaging does not, in fact, meet the applicable design and
manufacturing specification in the HMR.\11\
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\11\ Moreover, the Consumer Product Safety Commission (CPSC) has
the authority to require ``that a consumer product be marked with or
accompanied by clear and adequate warnings or instructions, or
requirements respecting the form of warnings or instructions.'' 15
U.S.C. 2056(a).
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Under the plain language of the Federal hazardous material
transportation law, requirements in the HMR govern the design,
manufacture, and marking of ``a package, container, or packaging
component that is represented, marked, certified, or sold as qualified
for use in transporting hazardous material in commerce.'' 49 U.S.C.
5103(b)(1)(A)(iii), 49 CFR 171.1(a). Any State requirement, including a
State's common law, on the ``designing, manufacturing, [or] marking * *
* a package, container, or packaging component that is represented,
marked, certified, or sold as qualified for use in transporting
hazardous material in commerce'' is preempted unless it is
``substantively the same as'' the requirements in the HMR. 49 U.S.C.
5125(b)(1)(E). The Elders have not pointed to, and PHMSA is not aware
of, any other Federal law that would authorize the common law tort
claims asserted by the Elders that the manufacturer of a DOT
specification 39 compressed gas cylinder should have designed the
cylinder (or any component thereof) in a different manner than--or
marked or labeled the cylinder with any information beyond that
required by--49 CFR 178.65.
IV. Ruling
Federal hazardous material transportation law preempts a private
cause of action which seeks to create or establish a State common law
requirement applicable to the design, manufacture, or marking of a
packaging, container, or packaging component that is represented,
marked, certified, or sold as qualified for use in transporting
hazardous material in commerce when that State common law requirement
would not be substantively the same as the requirements in the HMR.
Federal hazardous material transportation law does not preempt tort
claims that the packaging or packaging component failed to meet the
design, manufacturing, or marking requirements in the HMR or that a
person who offered a hazardous material for transportation in commerce
or transported a hazardous material in commerce failed to comply with
applicable requirements in the HMR.
V. Petition for Reconsideration/Judicial Review
In accordance with 49 CFR 107.211(a), any person aggrieved by this
decision may file a petition for reconsideration within 20 days of
publication of this decision in the Federal Register. A petition for
judicial review of a final preemption determination must be filed in
the United States Court of Appeals for the District of Columbia or in
the Court of Appeals for the United States for the circuit in which the
petitioner resides or has its principal place of business, within 60
days after the determination becomes final. 49 U.S.C. 5127(a).
This decision will become PHMSA's final decision 20 days after
publication in the Federal Register if no petition for reconsideration
is filed within that time. The filing of a petition for reconsideration
is not a prerequisite to seeking judicial review of this decision under
49 U.S.C. 5127(a).
[[Page 39571]]
If a petition for reconsideration is filed within 20 days of
publication in the Federal Register, the action by PHMSA's Chief
Counsel on the petition for reconsideration will be PHMSA's final
action. 49 CFR 107.211(d).
Issued in Washington, DC, on June 26, 2012.
Vanessa L. Allen Sutherland,
Chief Counsel.
[FR Doc. 2012-16240 Filed 7-2-12; 8:45 am]
BILLING CODE 4910-60-P