- 8/14/2019 Petition for Rulemaking on Scope and Use of "Preventability" (PDF)
- 8/14/2019 Making and Publishing Preventability Findings as Guidance without Due Process or Rulemaking – a Mistake of Epic Proportion (PDF)
- 9/9/2019 Preventability Determinations without Rulemaking: Why Should the Trucking Industry Care?