Our concerns with CPKC’s changes to tariff requirements for shippers of Toxic Inhalation Hazard (TIH)/Poison Inhalation Hazard (PIH) materials on the former KCSR network. Our respective organizations represent major CPKC customers that both ship and receive TIH/PIH materials. To prevent potential disruptions in critical supply chains, we urge you to delay the June 1, 2023, effective date for these tariff requirements by at least 60 days. In an April 17, 2023, notice to shippers of TIH/PIH commodities on the KCSR network, CPKC announced revisions to KCSR Rules Publications 9011-G and 9012 that will become effective June 1. These changes include a requirement for each TIH/PIH customer to take out and maintain a $100 million Commercial General Liability Insurance Policy and to fully indemnify the railroad for any incident that does not arise from the railroad’s negligence or willful misconduct.
