Jim Palmer - Comment

For over fifty years, Allied Universal Corporation, herein after “Allied”, has packaged, manufactured and distributed hazardous and non-hazardous chemicals for the sanitation of water, food, industrial and medical equipment throughout the southeastern and central United States. Allied has several packaging, manufacturing and distribution facilities, throughout the Southeastern United States. Allied is a member of the Chlorine Institute and the National Association of Chemical Distributors. Under the Responsible Distribution Program implemented company-wide, Allied is committed to protecting human health and the environment as well as fostering the proper, safe and secure handling and transporting of our products. As the Chief Executive Officer of Allied Universal Corporation, I am writing to state that Allied fully supports Petition P-1525. The petition as submitted provides a specification which shippers, like Allied, of TIH materials could utilize for new or replacement tank car needs while providing for continued safe and efficient rail transportation. The current lack of a specification with a definitive tank car life for new cars has caused great uncertainty in the face of the proposed federal regulation under docket FRA-2006-25169. This uncertainty poses the potential for a shortage of rail cars going forward. A shortage of chlorine and sulfur dioxide railcars in anyway would greatly hurt all of our business as well as potentially cause a public health crisis. Allied is a major supplier of water and waste water treatment chemicals throughout Florida as well as the Southeastern United States. We are therefore urging DOT to act favorably on Petition P-1525 which has the support of shippers, car builders and railroads. We request that DOT adopt the specification proposed in the petition as soon as practicable.