The era of shuffling through coffee-stained papers in the cab is over.

Effective Sept. 3, the Pipeline and Hazardous Materials Safety Administration is modernizing 49 CFR § 172.602 by granting domestic carriers and facility operators the option to maintain emergency response information (ERI) in an electronic format—rather than strictly on paper. The final rule acknowledges that modern hazardous materials operations already rely heavily on technology that is currently in use throughout the trucking industry.

“We commend PHMSA Administrator Paul Roberti and the agency for listening to industry stakeholders,” Ryan Streblow, National Tank Truck Carriers president and CEO, said in a news release. “This commonsense rule maintains immediate access to critical emergency information while eliminating an unnecessary regulatory burden. NTTC has consistently advocated for regulations that are performance-based, technologically current, and focused on measurable safety outcomes.

“We are especially proud that PHMSA recognized NTTC’s comments in the final rule and that our advocacy helped provide the agency with a strong industry case for making this commonsense change. NTTC’s voice and the real-world experience of our members carried considerable weight in demonstrating why this outdated paper requirement was no longer necessary.”

Immediate accessibility is non-negotiable

While the final rule introduces flexibility, PHMSA was clear in its Federal Register notice posted Aug. 4 that the standard for compliance remains strictly “performance-based.” The digital ERI must be immediately available at all times.

• Carriers and facility operators are entirely responsible for ensuring the reliability of their chosen electronic method.
• A lack of cellular signal will not excuse a carrier from compliance with the hazardous materials regulations (HMR).
• A device’s power loss will not excuse a carrier from HMR compliance.
• Device failure will not excuse a carrier from HMR compliance.

Because of these conditions, PHMSA notes that companies operating in remote areas with questionable connectivity should consider keeping electronic copies downloaded locally on the device or continuing to carry paper backups.

“PHMSA acknowledges [critics’] concerns but disagrees with the contention that electronic formats should be restricted to a supplemental role or that they are inherently unsafe due to connectivity limitations,” the agency stated.

Safety and cost savings realized

Industry advocates, including NTTC, stress that paper documents are rarely utilized by first responders during an active incident. In the event of a damaged tractor or incapacitated driver, paper ERI inside the cab is often completely inaccessible. Responders instead rely heavily on their own protocols, as well as the placards and specification plates attached directly to the cargo tank.

The shift away from mandatory paper copies also promises significant financial relief across the tank truck industry, the association asserted.

• One of NTTC’s largest member companies previously attributed over 10% of its hazmat violations specifically to ERI-related infractions.
• That same carrier reported spending approximately $3,500 every four years just to supply its fleet with updated paper documents.
• ERI compliance violations can result in fines of around $500 per incident.
• ERI violations also generate earned Compliance, Safety, Accountability (CSA) points, which negatively impact insurance rates.
• The Council on Safe Transportation of Hazardous Articles (COSTHA) indicated that allowing digital formats could save some members between $33,000 and $70,000 per Emergency Response Guidebook (ERG) cycle.

By alleviating these burdens, carriers can reduce violations, lower their insurance premiums tied to CSA scores, and fully leverage their existing digital compliance toolsets. “NTTC commends PHMSA for its leadership in modernizing regulatory frameworks to reflect operational realities,” Will Lusk, NTTC director of education and government relations, wrote in NTTC’s Aug. 27, 2025, letter.

“Allowing ERI in electronic format will enhance safety, improve efficiency, reduce costs, and allow the industry to further use digital compliance tools.”