Do Dangerous Goods Belong on Driverless Vehicles?

Posted on 3/23/2018 by Roger Marks and James Griffin, CDGP

Graphic-350.jpg[UPDATE 03/29/18] 

In today's Federal Register, PHMSA published a technical correction to its Request for Information on Regulatory Challenges to Safely Transporting Hazardous Materials by Surface Modes in an Automated Vehicle Environment.


US DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) this week released a request for information, or RFI, related to the development of automated technologies for transporting hazardous materials by surface modes, i.e., highway and rail.

By requesting input from industry hazmat shippers, carriers, and supply-chain professionals, PHMSA is taking the first step toward developing regulations to be applied to driverless vehicles carrying hazmat.

See the request in the Federal Register for information here.
Renew your hazmat shipper certification and take away 49 CFR compliance resources designed to simply compliance. The DOT Hazmat Ground Shipper Certification Workshop comes to Los Angeles, Las Vegas, Sacramento, Denver, Kansas City, and Minneapolis in April—and doesn’t stop there.  

Check out the full DOT hazmat training schedule.

Based on the current state of autonomous vehicles, we presume that while an employee may not “drive” the truck, a “safety engineer,” “operator,” or “attendant” will be in the vehicle during transport. The way we see it, having a trained hazmat employee in the truck will be critical--at least until the next leap in artificial intelligence.

Here are a few specific challenges that we foresee with a “headless horseman” handling hazmat:

Hazmat package inspection and acceptance check

For hazardous materials carriers, drivers carry out a crucial function; they inspect hazmat packages and determine whether the consignment complies with 49 CFR, then accept or reject the shipment accordingly.

Without a trained hazmat employee representing the carrier during cargo acceptance, will shippers be loading hazmat using the honor system? Speaking of loading hazardous materials…

Loading and unloading hazardous materials

Often, drivers take on the hazmat pre-transportation job function of loading dangerous goods onto the truckButton-350.jpg. The driver may need to segregate materials that are incompatible or block, brace, or secure the load to prevent shifting in transit. 

Without a driver to perform this function, shippers may need to expand their hazmat training programs to include 49 CFR training for loading and unloading materials. Or, an attendant (i.e., a “former driver”) will need hazmat training to perform this job safely and in compliance with 49 CFR.

Preserving and providing emergency response information

When a hazmat transportation incident occurs, the driver is the first responder on site, always. During an incident or release, drivers must grab the emergency response information that first responders will need and get free from danger.

How will local response teams get the emergency response information they need, if not from the driver? Will DOT set up an electronic system like EPA is launching for the Hazardous Waste Manifest? To provide accurate, timely response info to responders without a driver or attendant in the vehicle, local governments will need to collect and store a lot of data.

Driver attendance requirements for high-hazard materials

For high-hazard materials , bulk chemical shipments, and other materials covered under 49 CFR 172 Subpart I, US DOT requires the driver to attend the cargo at certain times to protect the shipment. Without a “driver,” driverless vehicles may need an “attendant” to perform the job of protecting cargo in transit. 

Collisions or incidents during hazmat transport

When a truck—whether carrying hazmat or not—collides with another vehicle, blows a tire, jack-knifes, or is otherwise disabled in transit, the driver is often responsible for warning motorists of the hazard by laying out flares, reflective flags, etc. Someone must be responsible for warning motorists in these situations, especially if the cargo is hazardous material and poses threats beyond traffic problems.

Maybe the full-on adoption of driverless vehicles for consumers and businesses is inevitable. But hazardous materials shipments are anything but rare and pose a host of new challenges in the automated driving age. On top of the challenges specific to hazmat, shippers and carriers will have to iron out basic transport issues like insurance and liability. System designers must address technology issues like hacking and software bugs. 

How comfortable are you with a driverless truck hauling hazmat through your neighborhood or next to you on the highway during your commute? Let us know on social media! Join the conversation on Lion’s Facebook or LinkedIn page today, or tweet at us @LionTechnology.

The comment period for this RFI is open until May 7, 2018. How to submit your comments.

Tags: 49, CFR, dangerous goods, DOT, hazardous materials, hazmat shipping

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