The U.S Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) is considering revisions to the Hazardous Materials Regulations (HMRs) that would authorize the use of an electronic alternative to the existing physical, paper-based hazard communication requirements.
The agency published a request for information in the Federal Register on Monday—and the first comments received are mixed.
While International Isotopes, an LTL shipper of ionic compounds, indicates it would consider implementing electronic hazard communication if authorized in the HMRs, a Commercial Vehicle Safety Alliance (CVSA)-certified hazardous materials inspector says electronic hazard communication should “absolutely not” be used as an alternative to current paper requirements.
“In a nutshell, I have concerns with availability, readability, accessibility, (and) training needs for truck drivers and trucking companies, cell phone coverage, etc.,” said Nick Wright, a technical trooper with the Kansas Highway Patrol, in his public comments filed the same day PHMSA published its request.
“Just consider how the implementation was of ELDs (electronic logging devices), and factor in the massive safety issue with hazardous materials.
“This seems like a disaster waiting to happen.”
The HMRs currently require that hazard communications—which includes shipping papers, train consists, dangerous goods manifests, notifications to the pilot in command, and emergency response information; as well as associated administrative documentation like DOT special permits, approvals, and registrations—be maintained as physical, printed documents during the transportation of hazardous materials.
However, widely adopted technologies could supplement or 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, PHMSA said. The agency 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.
PHMSA says its request for information is “to help determine the most effective mechanisms and potential impediments for implementing electronic hazard communication.”
International Isotopes seems to agree with the agency’s assertion.
The bulk of the manufacturer’s shipments are transported using Federal Express, which also provides the systems that generate its declarations of dangerous goods and air bills. So it’s primary concern is in regard to the compatibility of new electronic hazardous communications with the Federal Express system.
“If an electronic data exchange is going to be developed, then yes, the content and format should be standardized,” the company said in its July 12 comments. If the format isn’t standardized domestically and internationally, potential delays of sensitive “nuclear medicine shipments where the isotopes (have) short half-lives” could “make the product worthless by the time it is delivered.”
Wright raises several concerns in his comments, including the difficulty of accessing and reading electronic communications.
“It seems to me a hard copy of the documents simply can’t be beat,” he wrote. “In direct sunlight, it’s very difficult to read and share documents on a screen. For example, reading an electronic logging device (ELD) is very difficult when it’s sunny. Having to zoom in and scroll all around a screen to review the document is not easy. Usually only one person is able to see the screen at a time, rather than placing a piece of paper on a table and multiple people being able to review it. Cell phones and tablets usually automatically lock after a short time which creates additional inconveniences. Reviewing truck drivers’ hours of service (i.e., log books) has become far more burdensome with the advent of ELDs, and I feel allowing electronic production of hazmat shipping papers is a terrible idea.”
The trooper, who also is a DOT national training center hazmat instructor, says he foresees “very few benefits” to electronic hazard communications, but also acknowledged they’re probably “coming within 10 years.”
“However, perhaps certain hazmat should not be allowed to be transported with electronic shipping papers,” he said. “Whether that’s all placarding Table 1 materials, or all materials poisonous by inhalation, etc., would need to be decided. For simplicity, it could be no Table 1 materials and no bulk packages could utilize electronic shipping documents.”
Interested parties can submit comments on or before Sept. 9, PHMSA said. Comments received after that date will be considered “to the extent practicable.”