Earlier this month, the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a request for information (RFI) regarding electronic hazard communication alternatives. According to the PHMSA notice, the agency is seeking input on the potential use of electronic communication as an alternative to current physical documentation requirements for hazard communication. Notably, the agency is considering revisions to the Hazardous Materials Regulations (HMR) to authorize a performance-based electronic communication alternative to the existing physical, paper-based hazard communication requirements.

For the purposes of this RFI, “hazard communication” means shipping papers, train consists, dangerous goods manifests, notifications to the pilot in command, and emergency response information, as well as associated administrative documentation including DOT Special Permits, approvals, and registrations.

The HMR currently require that hazard communication be maintained as physical, printed documents during transportation. However, widely adopted technologies could supplement (or replace) the existing paper-based hazard communication system. They could also offer opportunities for improved emergency response and oversight, as well as increased efficiency in the operations of transportation networks. PHMSA anticipates that electronic communication would improve transportation safety, efficiency, and effectiveness by providing electronic access to the same required information currently contained in hazard communication documents. As such, PHMSA seeks public input to help determine the most effective mechanisms and potential impediments for implementing electronic hazard communication.

ACA will be submitting comments on the PHMSA proposal by the Sept. 9, 2022 comment deadline.

Contact ACA’s Rhett Cash for more information.