Comment Period Extended: Hazmat e-Communications

Posted on 8/26/2022 by Roger Marks

Update 08/26/22

US DOT PHMSA is extending the comment period for its notice requesting stakeholder input on potential benefits and drawbacks of electronic hazmat shipping papers, emergency response information, train consists, and other communications until October 24, 2022.
US DOT PHMSA invites hazardous materials shippers, carriers, emergency response organizations, and other stakeholders to share their thoughts about the potential for using electronic hazard communications as an alternative to the physical (i.e., paper) documentation currently required.

In the future, electronic communications could offer an alternative to the current hard-copy documentation requirements related to:
  • Hazmat shipping papers (49 CFR Part 172, Subpart C) 
  • Emergency response information (49 CFR 172, Subpart G)
  • Train consists (49 CFR 174.26) 
  • Notifications to the pilot in command (49 CFR 175.33) 
  • Dangerous cargo manifests (49 CFR 176.30) 
  • Shipping papers in motor vehicles (49 CFR 177.817) 

Electronic hazard communication could also affect DOT Special Permits (SPs), approvals, and registrations. DOT will accept comments on the Request for Information (RFI) until September 9 October 24, 2022.

Comments can be submitted online under the docket for “PHMSA Electronic Hazard Communication Project” at the website (Docket # PHMSA-2022-0043)

Comment Period Extended: Hazmat e-Communications

Questions for Hazmat Shippers

DOT poses two sets of questions in the RFI—one for shippers, transporters, and supply chain partners and one for emergency response and inspection organizations.

Some of the questions for shippers, transporters, and logistics facilitators to consider and comment on include (paraphrased):
  • Would you consider implementing electronic hazard communication if the HMR authorized it as an option?
  • What value could you gain by using electronic hazard communication?
  • Who should maintain and transmit the information—DOT/government, a third-party repository, an individual shipper/carrier based standard, or other?
  • Do you have concerns with DOT/other government agencies having permanent, historical access to the database, rather than access only during transportation?
  • To what extent would you participate in an electronic hazard communication alternative that was not fully multi-modal?
  • What if the electronic standard applied only to bulk transport of hazardous materials?
  • Should DOT prioritize electronic hazard communication for all quantities of hazardous materials shipments?
  • Do you anticipate resistance from others in the supply chain if you decide to adopt electronic hazard communication?
The RFI poses dozens of other questions and additional considerations for shippers and emergency response organizations to think about and comment on. The list of questions begins on page 41182 of the July 11 Federal Register.

Existing Electronic Hazard Communication Systems   

US EPA began phasing-in an electronic system for Hazardous Waste Manifests in 2018. Hazardous waste shipments make up a “small subset” of the 1.2 million hazmat shipments transported in the US every day, according to the PHMSA RFI.

In 2019, Transport Canada (in partnership with US DOT PHMSA) began a three-year “regulatory sandbox” to evaluate the feasibility of using electronic shipping documentation for the transport of dangerous goods. The pilot project involved rail carriers, highway carriers, and one aerial drone (UAS) carrier.

What Happens Next?

A request for information is a very early step in the rulemaking process. Public comments submitted in response to the RFI will provide PHMSA with insight into the regulatory community’s needs and concerns—and the potential challenges of implementing an electronic hazard communication system.

After the comment period closes, PHMSA may hold public meetings with stakeholders to further discuss a potential rule. Once they have considered stakeholder input, the next step is to publish an Advanced Notice of Proposed Rulemaking (ANPRM).

Lion News will track this activity and provide updates as the rulemaking process continues.

Upcoming Hazmat Training Workshops

Develop a step-by-step process to ship hazardous materials/dangerous goods by ground and air, in full compliance with US DOT and international regulations. These upcoming workshops are built to help satisfy 49 CFR (DOT) and IATA DGR training mandates for shippers and "hazmat employees."  
Hazmat Ground Shipper Certification (DOT)
Hazmat Air Shipper Certification (IATA) 

  Ground Shipper (DOT)          Air Shipper (IATA)
Nashville July 13–14 July 15
Dallas July 25–26 July 27
Orlando Aug. 3–4 Aug. 5
Houston Aug. 16–17 Aug. 18
Los Angeles          Sept. 14–15 Sept. 16
Chicago Oct. 5–6 Oct. 7

Later this year: Hazmat training workshops come to St. Louis, Atlanta, Philadelphia, and Hartford in Fall/Winter 2022. Find upcoming training at

US DOT requires training once every 3 years for all hazmat employees (49 CFR 172.704).
For air shippers, the IATA DGR requires training once every 2 years (IATA DGR 1.5)


Tags: hazard communication, hazmat shipping, hazmat shipping papers

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