June 20, 2002

Ms. Jackie Goff
Director, Intermodal Hazardous Materials Programs
Dockets Management System
U.S. Department of Transportation
Room PL 401
400 Seventh St., SW
Washington, DC 20590-0001

DOT Docket No. OST-01-10380; "Hazardous Materials: Knowledge Required for Civil Penalty Enforcement Proceedings" (Notice of public meeting and invitation to comment published April 9, 2002)

Dear Ms. Goff:

DGAC is an international, non-profit, educational organization devoted to promoting safety in the domestic and international transportation and handling of hazardous materials, substances and wastes. DGAC represents shippers, carriers of all modes, container manufacturers and reconditioners, emergency response and waste clean-up companies, and a variety of other companies and trade associations involved in the field of hazardous materials transportation.

We would like to raise an issue related to the topics of discussion listed in this notice. Once the enforcement policy issues discussed at the June 19, 2002 public meeting are resolved, we strongly recommend that penalty guidelines consistent with those published by RSPA in Appendix A to Subpart D of 49 CFR Part 107 be published by all of the operating administrations, including the Coast Guard. Besides those of RSPA, the only other penalty guidelines published in CFR format for general availability are those of the Federal Railroad Administration. It is vital that all regulated entities have access to such guidelines for all modes of transportation.

We appreciate this opportunity to comment.

Sincerely,

Alan I. Roberts
President