As we have seen over the last decade, there has been a trend shifting from paper copies of documentation to electronic in the dangerous goods world. To further this, PHMSA is considering revising the Hazardous Materials Regulations, which would authorize a performance-based electronic communication alternative to the existing physical, paper-based hazard communication requirement. This potential revision would enable and promote the use of electronic hazard communication. The term “hazard communication” in this case refers to shipping papers, train consists, dangerous goods manifests, notifications to the pilot in command, emergency response information, Special Permits, approvals, and registrations.
Why Might this Revision Take place?
The 49CFR currently requires that hazard communication be maintained as physical, printed documents during transportation, for example see 177.817 (e). The revision being discussed could essentially supplement, or potentially replace the existing paper-based hazard communication system, and offer opportunities for improved emergency response and oversight, as well as increased efficiency in the operations of transportation networks. The purpose for this potential revision is to improve transportation safety, productivity, and effectiveness by providing electronic access to the same required information currently contained in hazard communication documents. Prior to this, PHMSA has considered various alternatives to current requirements for paper-based hazardous materials documentation, primarily focusing on electronic shipping papers. Previous activities related to electronic shipping papers that are also being revisited include:
(1) The Environmental Protection Agency (EPA) Hazardous Waste E-Manifest
(2) Current DOT-SPs for electronic hazard communications information used in highway and rail transportation
(3) The Hazardous Materials Automated Cargo Communications for Efficient and Safety Shipments (HM-ACCESS) pilot project
(4) Integrated Communications, Information and Support Platform for Hazardous Materials Stakeholders Across Multiple Modes (HazSMART) research, and
(5) Transport Canada’s (TC) ongoing Regulatory Sandbox on Electronic Shipping Documents.
How can you Get Involved?
PHMSA is seeking the public’s input to help determine the most effective mechanisms and potential obstacles for implementing electronic hazard communication. Anyone that is interested in submitting comments on these potential revisions must do so on or before September 9, 2022, comments received after that date will be considered to the extent practicable. Please visit this link for details on how to submit comments to PHMSA as well as to review other specific information on these potential revisions.
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