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Moving Ahead for Progress in the 21st Century Act (MAP-21):
Congressional Report
January 2016
Prepared by Volpe for:
Pipeline and Hazardous Materials Safety Administration
Office of Hazardous Materials Safety
Washington, DC
Notice
This document is disseminated under the sponsorship of the Department of
Transportation in the interest of information exchange. The United States Government
assumes no liability for the contents or use thereof.
The United States Government does not endorse products or manufacturers. Trade or
manufacturers’ names appear herein solely because they are considered essential to
the objective of this report.
Paperless Hazard Communications Pilot Project
Acknowledgments
The Pipeline and Hazardous Materials Safety Administration wishes to thank the hazardous
materials (HM) community—HM stakeholders (shippers, carriers, emergency responders,
law enforcement inspectors); Federal, State, and local government agencies; HM/emergency
response training companies/educational associations; HM/emergency response
equipment/software developers/vendors; trade associations; freight forwarders/brokers; and
media companies—representing all transportation modes (Air, Maritime, Rail, and Roadway)
who contributed information to this report via discussion groups, posting comments to the
Hazardous Materials Automated Cargo Communications for Efficient and Safe Shipments
(HM-ACCESS) website, and/or completing the Impact Analysis Question Set. In particular,
PHMSA wishes to express their appreciation to all the pilot test participants who volunteered
their personnel, vehicles, equipment, and technology in support of the pilot tests.
Paperless Hazard Communications Pilot Project
Disclaimer
The HM-ACCESS Project described in this report was conducted over a four-year period from
2011 to 2015. While PHMSA has attempted to verify that the information collected during this
project is accurate as of the date of this report, some of the information in this report was
collected earlier in the project and may not reflect the current status of stakeholder e-system
initiatives and activities.
Paperless Hazard Communications Pilot Project
Contents
List of Figures ............................................................................................................................... iv
List of Tables ................................................................................................................................. iv
List of Abbreviations ................................................................................................................... vi
Executive Summary ..................................................................................................................... ix
1.
Introduction ............................................................................................................................0
2.
History and Background ........................................................................................................3
3.
2.1
PHMSA’s Regulatory Responsibility for HM Shipments .......................................................... 3
2.2
MAP-21 Paperless Hazard Communications Requirements....................................................... 3
2.3
PHMSA’s Activities Supporting Paperless Hazard Communications (before MAP-21) ........... 5
Consultation Activities with HM Stakeholders....................................................................6
3.1
3.2
High-Level Modal-Specific Assessments Regarding E-communication .................................... 6
3.1.1
Air Mode ........................................................................................................................ 6
3.1.2
Maritime Mode .............................................................................................................. 7
3.1.3
Rail Mode ...................................................................................................................... 8
3.1.4
Roadway Mode .............................................................................................................. 9
Communications with Federal Agencies and Private Companies Using E-systems................. 10
3.2.1 U.S. Federal Aviation Administration, MITRE, and the International Air Transport
Association E-Initiatives ........................................................................................................... 11
3.2.2
U.S. Department of Defense and U.S. Transportation Command E-systems .............. 12
3.2.3
U.S. Department of Energy E-System ......................................................................... 13
3.2.4 U.S. Federal Railroad Administration, Association of American Railroads, and
Affiliates E-HM Emergency Responder Communication Initiatives ....................................... 16
3.2.5
U.S. Environmental Protection Agency E-Manifest System ....................................... 17
3.2.6
United Parcel Service E-HM Communication ............................................................. 17
3.3 Discussions with HM Shippers, Carriers, Law Enforcement Inspectors, and Emergency
Responders.......................................................................................................................................... 18
4.
3.3.1
Discussions with HM Shippers .................................................................................... 18
3.3.2
Discussions with HM Carriers ..................................................................................... 20
3.3.3
Discussions with HM Law Enforcement Inspectors .................................................... 22
3.3.4
Discussions with Emergency Responders.................................................................... 26
Pilot Test Planning and Implementation Activities ...........................................................30
Paperless Hazard Communications Pilot Project
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4.1
Discussion Meetings on Emergency Response and Inspection Simulation Procedures ........... 31
4.2
60- and 30-Day Notices Regarding the Paperless HM Communications Pilot Tests ............... 31
4.3 Pilot Test Participant Selection, Inspection and Emergency Response Simulation, and Impact
Analysis Question Sets ....................................................................................................................... 32
5.
4.4
Submitting Pilot Test Information Collection Package to OMB and Obtaining Approval....... 34
4.5
Pilot Test Participant Selection ................................................................................................. 34
4.6
Orientation Webinars for Pilot Test Participants ...................................................................... 36
4.7
Pilot Test Coordination and Implementation ............................................................................ 36
Pilot Test Data .......................................................................................................................37
5.1
5.2
5.3
6.
7.
Pilot Test Volunteer Participants .............................................................................................. 38
5.1.1
Participating Shippers and Carriers.............................................................................. 38
5.1.2
Participating Emergency Response and Law Enforcement Inspection Organizations 40
Inspection Simulations .............................................................................................................. 41
5.2.1
Description of Roadway Inspection Simulations ......................................................... 43
5.2.2
Description of Maritime Inspection Simulations ......................................................... 47
5.2.3
Inspection Simulation Data .......................................................................................... 49
Emergency Response Simulations ............................................................................................ 52
5.3.1
Description of Emergency Response Simulations ....................................................... 53
5.3.2
Emergency Response Simulation Data ........................................................................ 56
Impact Analysis Data ...........................................................................................................67
6.1
Description of Data Collection Activity and Volunteer Participant Stakeholders .................... 67
6.2
Impact Analysis Data ................................................................................................................ 68
Data Evaluation ....................................................................................................................70
7.1
7.2
Stakeholder Group Findings ..................................................................................................... 70
7.1.1
Shippers ....................................................................................................................... 70
7.1.2
Carriers......................................................................................................................... 70
7.1.3
Law Enforcement Inspectors ....................................................................................... 70
7.1.4
Emergency Responders ................................................................................................ 71
Performance of Pilot Test Paperless Hazard Communications Systems .................................. 71
7.2.1
E-communication Systems Used During Pilot Tests ................................................... 72
7.2.2
Pilot Test Inspectors’ Feedback on the Inspection Simulations ................................... 74
7.2.3
Pilot Test Emergency Responders’ Feedback on the ER Simulations ......................... 78
7.2.4
Additional Pilot Test Findings ..................................................................................... 82
Paperless Hazard Communications Pilot Project
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7.3
7.4
8.
Safety and Security Impacts of Using E-systems ..................................................................... 83
7.3.1
Evidence from Incident Data ....................................................................................... 84
7.3.2
Other Considerations ................................................................................................... 85
Benefits and Cost Considerations ............................................................................................. 85
7.4.1
Public Safety Benefits .................................................................................................. 85
7.4.2
Administrative Cost Savings........................................................................................ 86
7.4.3
E-System Implementation Costs .................................................................................. 88
7.4.4
Benefits and Costs by Mode of Transportation ........................................................... 90
Conclusions............................................................................................................................92
8.1 Modal Shippers and Carriers Use of E-systems for Communicating HM Shipping Paper
Information ......................................................................................................................................... 92
8.2 Law Enforcement Inspectors Use of E-systems for Communicating HM Shipping Paper
Information ......................................................................................................................................... 93
8.3 Emergency Responders Use of E-systems for Communicating HM Shipping Paper
Information ......................................................................................................................................... 94
9.
8.4
Safety and Security Impacts of Using E-systems ..................................................................... 94
8.5
Cost-benefits and Impacts of Using E-systems ......................................................................... 95
Recommendations .................................................................................................................98
9.1 Recommendations for Incorporating E-systems into the Federal HM Transportation Safety
Program............................................................................................................................................... 98
9.2
Recommendations for Additional E-HM Pilot Tests and Research Studies ............................. 99
9.3
Other Recommendations Related to Use of E-systems............................................................. 99
9.4
Other Shipping Paper Considerations Recommended for Future Study ................................. 100
10. References............................................................................................................................101
Paperless Hazard Communications Pilot Project
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List of Figures
Figure 1. Benefits of E-systems .................................................................. Error! Bookmark not defined.
List of Tables
Table 1. Pilot Test Participants ................................................................................................................... 35
Table 2. Total Pilot Test Simulations.......................................................................................................... 37
Table 3. Pilot Test Simulations by Region ................................................................................................. 37
Table 4. Number of Actual Pilot Test Participants by Stakeholder Group ................................................. 38
Table 5. Pilot Test Inspection Simulation Information ............................................................................... 42
Table 6. Inspection Simulations—E-data Receipt Times ........................................................................... 49
Table 7. Documentation Reviewed During Inspection Simulations ........................................................... 50
Table 8. Devices and Electronic Data Exchange Languages Used by Shippers/Carriers to Send HM
Shipping Paper Information to Inspectors ..................................................................................... 50
Table 9. Devices, Electronic Data Exchange Languages, Communication Mechanisms, and Electronic
Data Formats Used by Inspectors to Receive the HM Shipping Paper Information...................... 51
Table 10. Pilot Test Emergency Response Simulation Locations .............................................................. 53
Table 11. ER Simulations—E-data Receipt Times ..................................................................................... 56
Table 12. Devices and Electronic Data Exchange Languages Used to Send E-Information to the
Dispatchers..................................................................................................................................... 57
Table 13. Devices, Electronic Data Exchange languages, Communication Mechanisms, and Electronic
Data Formats Used by PSAP Dispatchers to Receive E-Information............................................ 58
Table 14. Follow-Up Dispatch Actions ...................................................................................................... 59
Table 15. E-HM Communications with Emergency Responders Prior to On-Scene Arrival ..................... 59
Table 16. Air (Simulation 17)—Devices, Electronic Data Exchange Languages, Communication
Mechanisms, and Electronic Data Formats Used to Communicate with Emergency Responders
Prior to On-Scene Arrival .............................................................................................................. 60
Table 17. Rail (Simulations 18 and 21)—Devices, Electronic Data Exchange Languages, Communication
Mechanisms, and Electronic Data Formats Used to Communicate with Emergency Responders
Prior to On-Scene Arrival .............................................................................................................. 61
Table 18. Maritime (Simulation 19)—Devices, Electronic Data Exchange Languages, Communication
Mechanisms, and Electronic Data Formats Used to Communicate with Emergency Responders
Prior to On-Scene Arrival .............................................................................................................. 62
Table 19. E-HM Communications with Emergency Responders While On-Scene .................................... 63
Paperless Hazard Communications Pilot Project
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Table 20. Maritime (Simulation 19)—Devices, Electronic Data Exchange Languages, Communication
Mechanisms, and Electronic Data Formats Used to Communicate with Emergency Responders
On-Scene ........................................................................................................................................ 64
Table 21. Roadway (Simulation 20)—Devices, Electronic Data Exchange Languages, Communication
Mechanisms, and Electronic Data Formats Used to Communicate with Emergency Responders
On-Scene ........................................................................................................................................ 65
Table 22. Rail (Simulation 21)—Devices, Electronic Data Exchange Languages, Communication
Mechanisms, and Electronic Data Formats Used to Communicate with Emergency Responders
On-Scene ........................................................................................................................................ 65
Table 23. Impact Analysis Question Set Responses by Stakeholder Type ................................................. 67
Table 24. Use of Wireless or E-communication to Provide HM Information to Law Enforcement or
Emergency Response Personnel .................................................................................................... 68
Table 25. Receipt of Inspection or Incident HM Information via Wireless or E-communication .............. 69
Table 26. Agency/Company/Organization Currently Has E-System Capable of Managing and
Communicating HM Shipping Paper Information ......................................................................... 69
Table 27. Pilot Test E-communication Systems ......................................................................................... 72
Table 28. E-systems' Impact on Inspection Times ...................................................................................... 75
Table 29. E-system Benefits over Current Paper-Based System ................................................................ 76
Table 30. E-systems' Impact on Emergency Response Times .................................................................... 79
Table 31. E-System Benefits over Current Paper-Based System ............................................................... 80
Paperless Hazard Communications Pilot Project
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List of Abbreviations
Abbreviation
AAR
ACC
AEI
ANSI
ANSI X12
APCO
API
APL
ATA
CAD
CAPRI
CCTV
CFR
CGA
CG-FAC
CI
COSTHA
COTS
CSA
CVSA
DFAS
DGRs
DLA
DOD
DOE
DOT
DTEB
E-COMMERCE
E-DATA
EDI
E-HM
E-MANIFEST
EMS
EPA
ER
ERO
E-SYSTEM
FAA
FAX
FMCSA
FO
FR
FRA
FTE
GSA
Term
Association of American Railroads
American Chemistry Council
Automatic Equipment Identification
American National Standards Institute
ANSI EDI Standards
Association of Public-Safety Communications Officials
American Petroleum Institute
APL Limited
American Trucking Associations
Computer Aid Dispatch
Compliance Analysis and Performance Review Information
Closed-Circuit Television
Code of Federal Regulations
Compressed Gas Association
Cargo and Facilities Division (USCG)
The Chlorine Institute
Council on Safe Transportation of Hazardous Articles, Inc.
Commercial Off the Shelf
Compliance, Safety, and Accountability (an FMCSA program)
Commercial Vehicle Safety Alliance
Defense Finance and Accounting Services
Dangerous Goods Regulations
Defense Logistics Agency
Department of Defense
Department of Energy
Department of Transportation
Defense Transportation Electronic Business
Electronic Commerce
Electronic Data
Electronic Data Interchange
Paperless Hazardous Materials
Electronic Hazardous Waste Manifest
Emergency Medical Service
Environmental Protection Agency
Emergency Response
Emergency Response Organization
Paperless Hazardous Materials Communication System
Federal Aviation Administration
Facsimile
Federal Motor Carrier Safety Administration
Flight Object
Federal Register
Federal Railroad Administration
Full-Time Equivalent
General Services Administration
Paperless Hazard Communications Pilot Project
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Abbreviation
HM
HM-ACCESS
HMCRP
HMPIP
HMR
HW
IAFC
IAFF
IATA
ICAO
ICP
IMDG
IME
IP
IVODGA
JPEG
LEIO
LTL
MAP-21
MCMIS
MCSAP
MDT
NAFTD
NFPA
NOPIC
NPRM
NTSB
NTTC
NVFC
OMB
OOIDA
OREIS
ORI
ORNL
PDA
PDF
PHMSA
POC
PRA
PSAP
RFID
RITS
S/C
SAFER
SDDG
SDS
SP
Term
Hazardous Material(s)
Hazardous Materials Automated Cargo Communications for Efficient and Safe
Shipments
Hazardous Materials Cooperative Research Program (TRB)
Hazardous Materials Package Inspection Program
Hazardous Materials Regulations
Hazardous Waste
International Association of Fire Chiefs
International Association of Fire Fighters
International Air Transport Association
International Civil Aviation Organization
Information Collection Package
International Maritime Dangerous Goods
Institute of Makers of Explosives
Internet Protocol
International Vessel Operators Dangerous Goods Association
Joint Photographic Experts Group
Law Enforcement Inspection Organization
Less than Truckload
Moving Ahead for Progress in the 21st Century Act
Motor Carrier Management Information System (FMCSA)
Motor Carrier Safety Assistance Program
Mobile Data Terminal
North American Fire Training Directors
National Fire Protection Agency
Notification of Pilot–in-Command
Notice of Proposed Rulemaking
National Transportation Safety Board
National Tank Truck Carriers
National Volunteer Fire Council
Office of Management and Budget
Owner-Operator Independent Drivers Association
Operation Respond Emergency Information System
Operation Respond Institute
Oak Ridge National Laboratory
Personal Digital Assistant
Portable Document Format
Pipeline and Hazardous Materials Safety Administration
Point-of-Contact
Paperwork Reduction Act
Public Service Answering Point
Radio Frequency Identification
Radio Frequency Identification Transportation System
Shipper/Carrier
Safety and Fitness Electronic Records
Shipper’s Declaration for Dangerous Goods
Safety Data Sheet
Special Permit
Paperless Hazard Communications Pilot Project
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Abbreviation
TRB
TURNKEY
UCOR
UN
UPS
URL
USCG
USTRANSCOM
WATCO
XML
Term
Transportation Research Board
Turnkey Technical Services, LLC
URS—CH2M Oak Ridge LLC
United Nations
United Parcel Service
Uniform Resource Locator
The United States Coast Guard
United States Transportation Command
Watco Companies, LLC
Extensible Markup Language
Paperless Hazard Communications Pilot Project
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Executive Summary
The Hazardous Materials Regulations (HMR)—49 Code of Federal Regulations, Parts 171–180—require
persons who offer hazardous materials (HM) for transportation in commerce to describe key hazard
communication information on a shipping paper. Currently, the HMR requires a paper copy of the
shipping paper to accompany HM in transport. After the HM is no longer in transport, shippers and
carriers must retain and make accessible the hardcopy shipping paper or an electronic image of it for one
year. For a hazardous waste, the shipping paper copy must be retained for three years after the material is
accepted by the initial carrier. For all other HM, the shipping paper must be retained for two years after
the material is accepted by the initial carrier. Consideration for allowing the use of electronic
communication while HM is in transport is the next step in the evolution of hazard communication.
Section 33005 of the Moving Ahead for Progress in the 21st Century Act (MAP-21) authorizes the
Secretary to conduct pilot projects to evaluate the feasibility and effectiveness of using paperless hazard
communications systems. In support of this authority, PHMSA conducted pilot projects in 2015 to test the
feasibility and effectiveness of using paperless hazardous materials (e-HM) communication systems (esystems) to communicate HM shipping paper information while the HM is in transport. In accordance
with MAP-21, this report provides a summation of the information and feedback obtained regarding the
feasibility and effectiveness of using e-systems and provides a recommendation on whether e-systems
should be incorporated into the Federal hazardous material transportation safety program permanently
under Chapter 51 of Title 49, of the United States Code.
Information and feedback presented within this report were obtained from:
Consultation activities (between 2012 and 2015) with HM stakeholders, including Federal and
State authorities, emergency responders, law enforcement, and the HM industry (shippers and
carriers), with the objective of obtaining feedback on the priorities, gaps, concerns, and
operational requirements associated with using e-systems;
Execution of 21 pilot tests (between February 17, 2015 to May 15, 2015) with volunteer entities
who prepare HM for shipment (i.e., shippers), transport HM (i.e., carriers), inspect HM shipments
(i.e., law enforcement investigators), and respond to accidents involving HM (i.e., emergency
responders). The pilot tests were conducted within five U.S. regions (Western, Central,
Southwestern, Southern, and Eastern) and included one rural area (in accordance with MAP-21).
The objective of the tests was to collect data regarding the feasibility, effectiveness, and safety
associated with the electronic transfer of HM shipping paper data during inspection and
emergency response simulations utilizing pilot test participants’ existing equipment and
resources. Hard copies of HM shipping papers still accompanied each HM shipment, as required
by current regulations; and
A voluntary impact analysis, collected from a data question set completed online by 92
respondents (between February 17, 2015, and May 15, 2015). The respondents represented
different HM stakeholders, including Federal and State authorities, emergency responders, law
enforcement officials, and different segments of the industry (shippers, carriers, freight
forwarders, HM trainers, HM equipment vendors, etc.). The objective of the question set was to
collect information to aid in a qualitative assessment of potential impacts associated with using e-
Paperless Hazard Communications Pilot Project
ix
systems to communicate HM shipping paper information.
Findings and Conclusions
Modal Shippers and Carriers
Many shippers in all modes already have e-systems containing HM shipping information, and Air,
Maritime, and Rail Mode carriers have e-systems in place for communicating HM shipping paper
information. As long as they are allowed to use performance-based e-systems that provide them with
flexibility to conduct their businesses in a cost-effective and efficient manner, these shippers and carriers
should be able to use e-systems effectively for communicating HM shipping paper information.
In general, HM transport by roadway carriers is significantly different from, and in some cases more
complex than, their modal counterparts. Although some roadway carriers already have established esystems, the feasibility and effectiveness of communicating HM shipping paper information may be
difficult or impractical for other roadway carriers. For example, those who require an HM paper
documentation trail, cannot afford to purchase or invest in an e-system; do not have the onboard
technology for receiving and transmitting e-HM information; or transport HM in areas with poor Internet
connectivity.
Shippers and carriers looking to utilize e-systems for sending and receiving e-HM data need to ensure that
accurate and complete e-HM data can be accessed at all times and shared promptly and that permission
protocols for authorizing shipper and carrier personnel to provide e-HM information to inspectors, and
emergency responders are developed and implemented. Furthermore, shippers and carriers will need to be
able to communicate the e-HM information in an open, easily transferable and readable e-data format.
Carriers in all modes utilizing e-systems will need to apply a visual aid (such as a placard) to indicate HM
shipping paper information is being communicated electronically and a visual indication of how to obtain
the e-HM information [such as a point-of-contact (POC) telephone number or website] to the exterior of
HM transportation conveyances. These visual signals are important for inspectors and emergency
responders to recognize conveyances transporting HM using e-HM shipping papers and know how to
obtain the e-HM data. Carriers who want to participate in e-HM data sharing need to ensure their
operators are provided with devices capable of receiving, storing, and transmitting electronic HM
information, for quick access and sharing of HM information with inspectors and emergency responders.
Operators need to be provided with a device to provide e-HM data directly to inspectors and emergency
responders when HM is being transported within areas of known Internet connectivity issues.
Law Enforcement Inspectors
The Air and Rail Mode industry practices require the HM shipping paper information be provided
electronically before the HM is accepted by the carrier for transport. Industry practices in both modes
require operations personnel to compare the hardcopy HM shipping paper information with the physical
HM before transport. As the HM shipping paper information is currently required to be provided
electronically, inspectors in these modes should be able to use e-systems effectively to receive and review
the e-HM information. Many inspectors in these modes already possess electronic devices capable of
receiving e-HM data; however, these devices are not standardized and as such devices may need to be
procured for some inspectors.
Paperless Hazard Communications Pilot Project
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Currently, many HM inspectors in the Maritime Mode (the USCG container inspectors) are not equipped
with electronic devices either capable of or permitted to be used for, receiving e-HM shipping paper
information during the administration of HM container inspections. The USCG purchased electronic
tablets in 2014 for inspectors to use for accessing reference materials while conducting field activities.
The USCG recommends that the use of such devices be expanded in the future; these devices could
potentially be used by maritime container inspectors to access e-HM shipping paper information during
container inspection activities.
Roadway inspectors are provided laptops and have access to a variety of databases for searching and
storing HM information. These roadway inspectors should be able to receive e-HM shipping paper
information effectively from shippers and carriers who have e-systems capable transmitting the e-HM
information.
Emergency Responders
Emergency responders in urban areas with existing response systems and networks should be capable of
effectively receiving and transmitting HM shipping paper information via e-systems. However, some
emergency response organizations are volunteer-based or exist in rural or geographically challenging
areas with limited Internet connectivity. Some of these challenged areas may also have limited access to
the electronic devices needed not be able to obtain e-HM data at the scene of an accident or incident, and
directly from the carrier or shipper until solutions to these issues are identified and implemented. These
emergency response organizations will need to rely on verbal communication of HM data to on-scene
emergency responders using their other existing layered and redundant backup systems to receive HM
shipping paper information from shipper’s and carrier’s e-systems.
E-systems’ Impacts, Benefits, and Costs
The e-system concept requires, at least, an equivalent level of safety and security as compared to the
current hardcopy-based system of hazard communication. The following pieces of evidence provide some
insight into e-systems’ potential safety and security impacts:
Some e-systems may be able to provide improved safety by increasing the accuracy and
timeliness of information received by first responders;
E-systems can reduce the possibility of HM shipping documents being lost or damaged, and
software interfaces can contribute to reducing data source errors, such as misspellings;
E-systems that have redundancy capabilities are potentially more robust than hardcopy shipping
papers in the event of an accident or incident;
In the case of a serious vehicle crash or fire, the ability to obtain HM information electronically—
and without having to approach the vehicle—may improve safety for responders and improve the
effectiveness of their efforts; and
E-systems that have been verified and tested as being protected from unauthorized access may
provide better security of HM information, by requiring vetted, authorized users to provide user
authentication information before gaining access to HM information.
Additional e-systems’ safety and security impact considerations include impacts associated with outages
or telecommunications problems; impacts if an e-system is hacked, and associated HM data is
Paperless Hazard Communications Pilot Project
xi
compromised/altered/deleted; and e-system limitations associated with situations such as occasional
system outages. The full magnitude of these safety and security impacts is difficult to quantify until more
operational experience with e-systems is gained.
The cost-benefits of electronic hazard communication for shippers and carriers are variable across modes,
but may have commonalities in administrative areas, such as decreasing redundant data entries—which in
turn reduces data entry errors and associated delays. More direct administrative cost savings would vary
across different organizations, industries, and e-system formats, the reduction in time required to prepare
shipping papers electronically is expected to be more pronounced for shippers than for carriers, and for
larger firms than for smaller firms. There may also be significant cost-benefits for companies that can
decrease HM transit times, which could lead to broader supply chain benefits (e.g., lower inventory
costs).
Transitioning from the current paper-based system to an e-system may entail substantial implementation
costs. These costs are likely to vary among transportation modes, due to differences in their existing use
of e-systems and the nature of their HM operations. Even within particular modes, the impacts will vary
based on factors such as business type and size; the range of HM commodities transported; whether an esystem is already being utilized; whether HM information can be accessed via or added to the e-system’s
data fields; and if the business can sustain profitability while, and/or identify a dual-benefit for,
implementing an e-system. Development, implementation, operation, and maintenance costs need to be
considered, as these costs will vary widely depending on the number of employees requiring training on,
and the complexity of, the e-system. Conversion to an e-HM approach will likely be less costly for
shippers and carriers that are already using e-systems and will provide more immediate business benefits
in terms of reduced administrative costs.
Another cost-benefit consideration is that hardcopy shipping papers are used in some modes and
industries for purposes other than HM communication. As such, the additional business processes covered
by the hardcopy shipping papers could potentially be affected by transitioning to an e-system. Also,
companies, especially those in the Roadway Mode, facing challenges such as e-system implementation
impediments, problems with electronic communication mechanisms, and the existence of “dead spots” in
wireless communication will likely face additional technological costs and complexities in transitioning to
an e-system.
Paperless Hazard Communications Pilot Project
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Recommendations
Based on the findings and information collected under this study, Volpe believes e-systems can be a
feasible and effective alternative to hardcopy documentation for communicating HM shipping paper
information during the transport of HM. Volpe also believes e-systems can provide an equivalent level of
safety and security already provided by hardcopy shipping papers if certain performance standards are
met.
Consequently, Volpe recommends considering a rulemaking to modify the HMR to permit the use of esystems for communicating e-HM shipping paper information if a set of minimum performance-based
standards are met. Recommended performance criteria to be evaluated and defined during the rulemaking
process include requiring:
An identified POC is available for providing the e-HM information 24 hours per day, seven days
per week;
All HM shipping paper information is provided electronically on-demand within a defined time
interval after the initial request (Note: DOT-SP 15747 in Appendix H: UPS Special Permit 15747
requires that the e-HM shipping paper information be provided “without delay” to emergency
responders and inspectors in a single transmission within five minutes from when the initial
request is received by the UPS call center);
Shippers and carriers develop, document and train (initial and refresher) affected staff on their
equipment, procedures, and security protocols associated with providing e-HM communications
in HM transportation;
A performance definition for paperless communication that is flexible; permits the use of
different technologies (because of variations in existing systems, across industry, modes, and
continually evolving technologies); and provides the e-HM information in an open, easily
transferable and readable e-data format (such as, but not limited to, pdf) is developed;
A standardized defined visual aid (such as a placard) indicating that the HM shipping paper
information will be communicated electronically, along with a means to obtain the e-HM
information (such as a POC telephone number or website) is visible on the exterior of the
transportation conveyance; and
In areas with known Internet connectivity issues, transportation conveyance operators must have
the means to directly provide the e-HM information to local HM inspectors and emergency
responders (e.g., print the HM shipping paper information directly from a device in the
transportation conveyance, show the HM shipping paper information on a laptop/tablet screen,
etc.), and are provided with a backup procedure for obtaining the HM shipping paper information
and providing the HM shipping paper information to local HM inspectors and emergency
responders.
Paperless Hazard Communications Pilot Project
xiii
PHMSA also recommends that additional pilot tests/research studies involving a larger diverse set of
stakeholders in all modes under various conditions and using a variety of electronic devices and scenarios
be conducted to test and examine the recommended minimum e-system performance standards. These
additional pilot tests/research studies will provide data to support rulemaking considerations to allow the
use of e-systems for communicating e-HM shipping paper information while the HM is in transport.
In addition, the DOT, the EPA, and other agencies should continue to coordinate efforts for developing
and implementing electronic communications, including EPA’s E-Manifest Program.
Paperless Hazard Communications Pilot Project
xiv
1. Introduction
The Hazardous Materials Regulations (HMR)—49 Code of Federal Regulations (CFR), Parts 171–180—
require a person who offers HM for transportation in commerce to describe the HM on a shipping paper
in the manner required in 49 CFR Part 172, Subpart C. The shipping paper requirements identify key
hazard communication information [i.e., United Nations (UN) number, proper shipping name, hazard
class, Packing Group, type and quantity of packaging, and emergency response telephone number].
Unless an exception from the shipping paper requirements is provided in the regulations, a paper copy of
the shipping paper must accompany HM during transportation. A shipping paper includes ‘‘a shipping
order, bill of lading, manifest or other shipping document serving a similar purpose and containing the
information required by §§ 172.202, 172.203, and 172.204’’ (49 CFR 171.8, the definition of ‘‘shipping
paper’’). Hazardous waste (HW) manifest ‘‘may be used as the shipping paper’’ if it contains all the
information required by Part 172, Subpart C [49 CFR 172.205(h)]. The rationale behind a paper-based
system is to convey the necessary information in a consistent manner that is widely understood and
accepted by all regulated entities, law enforcement, and emergency responders.
In 1994, Congress amended the Federal HM transportation law to require that, after an HM ‘‘is no longer
in transportation,’’ all offerors and carriers of a HM must retain the shipping paper ‘‘or electronic image
thereof for a period of one year to be accessible through their respective principal places of business’’ [49
U.S.C. 5110(e), added by Pub. L. 103–311, Title I, § 115, 108 Stat. 1678 (Aug. 26, 1994)]. An electronic
image includes an image transmitted by a facsimile (Fax) machine, an image on the screen of a computer,
or an image generated by an optical imaging machine. In 2002, the Research and Special Programs
Administration (the predecessor to PHMSA) issued final rules (67 FR 46123 and 67 FR 66571) further
amending Parts 172, 174, 175, and 176 of the HMR regarding the retention and information requirements
associated with shipping papers; these final rules require shippers and carriers to retain a copy of each
HM shipping paper, or an electronic image thereof, for a period of 375 days1 after the date the HM is
accepted by the initial carrier. In 67 FR 66571, stipulates that HM shipping papers must be accessible at
or through the shippers’ and carriers’ principal places of business and must be made available, upon
request, to an authorized official of a Federal, State, or local government agency at reasonable times and
locations. For a hazardous waste, the shipping paper copy must be retained for three years after the
material is accepted by the initial carrier. For all other HM, the shipping paper must be retained for two
years after the material is accepted by the initial carrier. Consideration for allowing the use of electronic
communication (e-communication) while HM is actually in transportation is the next step in the evolution
of hazard communication.
Title III—Hazardous Materials Transportation Safety Improvement Act of 2012, Section 33005,
“Paperless Hazard Communications Pilot Program” of the “Moving Ahead for Progress in the 21st
Century Act” (MAP-21) provided PHMSA the authority to conduct pilot projects to test the feasibility
and effectiveness of using paperless hazardous materials (e-HM) communication systems (e-systems) to
communicate HM shipping paper information. MAP-21, Section 33005 is provided in Appendix A:
MAP-21, Section 33005.
1
If the HM is an HW, the shipping paper, or an electronic image thereof, must be maintained by the shippers and carriers for three years after the
material is accepted by the initial carrier (67 FR 46123 and 67 FR 66571).
Paperless Hazard Communications Pilot Project
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The purpose of this report is to communicate information and feedback obtained to date regarding the
feasibility and effectiveness of using e-systems to provide HM shipping paper information during the
transport of HM, and to provide a recommendation to Congress as to whether e-systems should be offered
as an alternative to hardcopy shipping papers for HM stakeholders whose e-systems meet minimum
performance standard metrics.
Chapter 2 provides historical and background information regarding PHMSA’s responsibilities associated
with HM shipments (Section 2.1) and its paperless hazard communications efforts (Section 2.3). It also
includes the MAP-21 paperless hazard communication requirements for PHMSA (Section 2.2).
Chapter 3 identifies consultation activities between PHMSA and HM stakeholders conducted between
2012 and 2015. These activities included communicating with Federal and private companies currently
using e-systems (Section 3.2) and holding discussions and meetings with HM stakeholders (i.e., shippers,
carriers, law enforcement inspectors, and emergency responders) (Section 3.3). This chapter also includes
assessments by mode regarding e-communication (Section 3.1).
Chapter 4 describes the pilot test planning and implementation activities, including facilitating meetings
to discuss pilot test emergency response and inspection simulation procedures (Section 4.1); publishing
pilot test 60-Day and 30-Day Federal Register Notices (Section 4.2); developing pilot test participant,
simulation, and impact analysis question sets (Section 4.3); submitting a pilot test information collection
package (ICP) to, and obtaining approval from, the Office of Management and Budget (OMB) (Section
0); selecting pilot test participants (Section 4.5); developing and organizing regional pilot test participant
webinar orientation sessions (Section 4.6); and conducting pilot test coordination and implementation
activities (Section 4.7).
The pilot test inspection and emergency response simulation question sets (Appendix L: Pilot Test
Inspection Simulation Question Set and Appendix M: Pilot Test Emergency Response Simulation
Question Set, respectively) were designed to evaluate the use of e-systems during actual HM shipments to
transfer HM information between HM stakeholders (i.e., shippers, carriers, law enforcement inspection
personnel, and emergency responders); the pilot test data is provided in Chapter 5. The objective of the
pilot test simulations was to gather limited, non-generalizable data on the benefits and limitations of using
e-systems to communicate HM shipping paper information in all transportation modes (Air, Maritime,
Rail, and Roadway) and to assess whether e-systems offer an equivalent or better level of safety as
currently provided by hardcopy shipping papers.
In conjunction with the pilot test simulations, PHMSA developed a voluntary impact analysis question set
(Appendix N: Pilot Test Impact Analysis Question Set) for the wider HM community (HM stakeholders;
Federal, state, and local government agencies; HM/emergency response training companies/educational
associations; HM/emergency response equipment/software developers/vendors; trade associations; freight
forwarders/brokers; and media companies) to report their experiences regarding the use, development,
cost, benefits, and challenges associations with e-systems. Chapter 6 includes the impact analysis.
Paperless Hazard Communications Pilot Project
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Analysis and evaluation of the pilot test and impact analysis data are provided in Chapter 7. This chapter
provides stakeholder and PHMSA’s viewpoints and opinions on the safety and security impacts, as well
as cost/benefits considerations, of using e-communications and e-systems to convey HM shipping paper
information.
Some stakeholders provided viewpoints on information that should be required on a shipping paper and
the mandate of a specific shipping paper form/order of information. While this information is beyond the
scope of this report, it is provided in Appendix C: Information Collected Outside Scope of Report but
Related to Project as related information for potential consideration.
Chapter 8 provides PHMSA’s conclusions regarding the feasibility and effectiveness of using e-systems
to provide HM shipping paper information to all HM stakeholders (i.e., shippers, carriers, law
enforcement inspectors, and emergency responders) during the transport of HM in all modes.
Chapter 9 provides PHMSA’s recommendations to Congress as to whether e-systems should be offered as
an alternative to hardcopy shipping papers for HM stakeholders whose e-systems meet minimum
performance standard metrics.
Paperless Hazard Communications Pilot Project
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2. History and Background
This chapter provides information on PHMSA’s regulatory role with HM shipments; MAP-21
requirements for paperless hazard communications; PHMSA’s paperless hazard communications
activities starting in 2007; and PHMSA’s activities supporting MAP-21 requirements before conducting
the 2015 pilot tests.
2.1 PHMSA’s Regulatory Responsibility for HM Shipments
The HMR (49 CFR, Parts 171-180) establish PHMSA as the Federal agency responsible for regulating
the safe and secure transportation of HM in commerce. The HMR require a person who offers HM for
transportation in commerce to describe the HM on a shipping paper in the manner required in 49 CFR
Part 172, Subpart C. The shipping paper requirements identify key hazard communication information
[i.e., UN number, proper shipping name, hazard class or division number, Packing Group, total quantity
of HM (except for HM transported by aircraft), total net mass per package (for HM transported on
aircraft), number and type of packages, shipper’s certification statement, and emergency response
telephone number]. Unless an exception from the shipping paper requirements is provided in the
regulations, a paper copy of the shipping paper must accompany HM during transportation. A shipping
paper includes ‘‘a shipping order, bill of lading, manifest or other shipping document serving a similar
purpose and containing the information required by §§ 172.202, 172.203, and 172.204’’ (49 CFR 171.8,
the definition of ‘‘shipping paper’’). An HW manifest may be used as the shipping paper if it contains all
the information required by Part 172, Subpart C [49 CFR 172.205(h)].
Copies of shipping papers, or an electronic image thereof, must be retained for two years (three years if
the HM is an HW) after the HM is accepted by the initial carrier by each person who provides a shipping
paper [49 CFR 172.201(e)].2
2.2 MAP-21 Paperless Hazard Communications Requirements
The “Moving Ahead for Progress in the 21st Century Act” (MAP-21)3, defines “paperless hazard
communications system” as “the use of advanced communications methods, such as wireless
communications devices, to convey hazard information between all parties in the transportation chain,
including emergency responders and law enforcement personnel.” The format of communication may be
equivalent to that used by the carrier.” Section 33005 of MAP-21 also indicates that PHMSA may
conduct pilot projects to evaluate the feasibility and effectiveness of using e-systems to communicate HM
shipping paper information. MAP-21 specifies that the pilot projects conducted by PHMSA:
Include at least one rural area;
2
Each shipping paper must include the date of acceptance by the initial carrier. For Rail, vessel, and Air shipments, the initial carrier may use the
date of the shipment’s waybill, airbill, or bill of lading in place of the date of acceptance. See 49 CFR 172.201(e).
3
Public Law 112-141, Division C—Transportation Safety and Surface Transportation Policy, Title III—Hazardous Materials Transportation
Safety Improvement Act of 2012, Section 33005, “Paperless Hazard Communications Pilot Program”
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3
Include consultation with organizations representing fire services personnel, law enforcement and
other appropriate enforcement personnel, other emergency response providers, HM shippers, HM
carriers in all modes [Air, Maritime (water), Rail, and Roadway], and employees of shipper and
carriers; and
Cannot waive the current shipping paper requirements.4
Additionally, MAP-21 requires PHMSA to submit a final report to the Committee on Commerce,
Science, and Transportation (U.S. Senate) and the Committee on Transportation and Infrastructure (U.S.
House of Representatives) by October 1, 2014,5 that includes the following information:
A detailed description of the pilot projects;
An evaluation of each pilot project, including an evaluation of the performance of each paperless
hazard communications system;
An assessment of the safety and security impact of using e-systems, including any impact on the
public, emergency response, law enforcement, and the execution of inspections and
investigations;
An analysis of the associated benefits and costs of using e-systems for each mode of
transportation; and
A recommendation that incorporates the information above as to whether e-systems should be
incorporated into the Federal HM transportation safety program permanently under Chapter 51 of
Title 49, United States Code.
This report is intended to satisfy the Map-21 final report requirement to these Congressional committees.
Refer to Appendix A: MAP-21, Section33005 for Section 33005 of MAP 21, Paperless Hazard
Communications Pilot Program.
4
See 49 CFR Part 172, Subpart C (Shipping Papers); 174.24 (Carriage by Rail—Shipping Papers); 175.30 and 175.33 (Carriage by Aircraft—
Inspecting Shipments and Shipping Paper and Notification of Pilot-in-Command); 176.24 (Carriage by Vessel—Shipping Papers); and 177.817
(Carriage by Public Highway—Shipping Papers) to carry hardcopy shipping papers on all HM transportation conveyances while the HM is in
transport.
5
In letters submitted to members of the Committee on Commerce, Science, and Transportation, the Committee on Transportation and
Infrastructure, and the Committee on Energy and Commerce on September 30, 2014 by PHMSA Administrator Cynthia L. Quarterman, PHMSA
provided a status update on its MAP-21, Section 33005 activities conducted to-date, including obtaining Office of Management and Budget
(OMB) approvals under the Paperwork Reduction Act (PRA) and a revised anticipated report submittal date to Congress in 2015. Copies of these
letters are provided in Appendix D: Letters to Congressional Committees.
Paperless Hazard Communications Pilot Project
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2.3 PHMSA’s Activities Supporting Paperless Hazard
Communications (before MAP-21)
In 2007, PHMSA began conducting activities to improve understanding of paperless hazard
communications. These activities included:
Building a cooperative effort between transportation entities and regulatory agencies;
Publishing a public meeting notice in 2008 on the use of electronic data (e-data) sharing; and
Collaborating with two Transportation Research Board (TRB) Hazardous Materials Cooperative
Research Program (HMCRP) reports (Reports 46 and 87) to examine better approaches to
communicating HM information to emergency responders during transportation.
These activities laid the groundwork for PHMSA to begin understanding the challenges and opportunities
in the HM community regarding paperless hazard communications, and allowed PHMSA to build upon
similar efforts conducted, and information learned, by other reputable organizations as it began
conducting efforts in support of the MAP-21 requirements.
6
Report 4, Project HM-04: Emerging Technologies Applicable to Hazardous Materials Transportation Safety and Security, 2011.
http://onlinepubs.trb.org/onlinepubs/hmcrp/hmcrp_rpt_004.pdf.
7
Report 8, Project HM-05: Evaluation of the Use of Electronic Shipping Papers for Hazardous Materials Shipments, 2012.
http://onlinepubs.trb.org/onlinepubs/hmcrp/hmcrp_rpt_008.pdf.
Paperless Hazard Communications Pilot Project
5
3. Consultation Activities with HM
Stakeholders
PHMSA began conducting activities in support of the MAP-21 requirements in 2012. These activities
included conducting:
Assessments of general e-communications used within each transportation mode;
Communications with Federal stakeholders and private companies using e-systems; and
Discussions and meetings with HM shippers, carriers, law enforcement inspectors, and
emergency responders.
Each of these activities is further described in the following sections.
3.1 High-Level Modal-Specific Assessments Regarding Ecommunication
3.1.1
Air Mode
The Air Mode currently has sophisticated security protocols for other e-records (e.g., passenger
information), so e-HM communication should fit within its existing protocols. In addition, international
air shipments already allow for e-dangerous goods records via the International Civil Aviation
Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air8 and the
International Air Transport Association’s (IATA’s) Dangerous Goods Regulations (DGRs), the global
reference for shipping dangerous goods, including HM, by air and the standard recognized by airlines,9 so
it should be possible to leverage these international allowances for e-HM shipping papers. While the main
type of HM transported on airplanes is medical grade Class 7 radioactive substances;10 all HM are
required to be declared before shipment.
49 CFR 175.33 requires that a copy of the shipping paper accompany the HM shipment it covers during
its transportation aboard the aircraft and that the aircraft operator provides the pilot-in-command with the
following accurate and legible written information (i.e., the notification of pilot–in-command, or NOPIC)
before the aircraft departs:
Proper shipping name, hazard class, and HM identification number, as specified in 49 CFR
172.101 or the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air;
Total number of packages;
Net quantity or gross weight for each package [except those containing Class 7 (radioactive)
8
http://www.icao.int/safety/dangerousgoods/pages/technical-instructions.aspx.
http://www.iata.org/whatwedo/cargo/dgr/.
10
Hazardous Materials Cooperative Research Program, Transportation Research Board, Project HM-05.
9
Paperless Hazard Communications Pilot Project
6
materials];
Location of the packages aboard the aircraft;
Confirmation that no damaged or leaking packages have been loaded on the aircraft;
For Class 7 (radioactive) materials, the number of packages, overpacks or freight containers, their
category, transport index (if applicable), and their location aboard the aircraft;
Date of the flight;
Telephone number of a person not aboard the aircraft from whom the information contained in
the notification of pilot-in-command can be obtained;11
Confirmation that the package must be carried only on cargo aircraft if its transportation aboard
passenger-carrying aircraft is forbidden; and
An indication, when applicable, that HM is being carried under terms of a special permit.
Also, a copy of the written NOPIC shall be readily available to the pilot-in-command during flight, and
emergency response information required by 49 CFR 172, Subpart G must be maintained in the same
manner as the written NOPIC during HM transport aboard the aircraft. This information must be readily
accessible at the airport of departure and the intended airport of arrival for the duration of the flight leg.
The airlines historically used electronic data interchange (EDI) language for inputting cargo booking and
related financial accounting information, as EDI provides a structured message defined for teletype. Some
air carriers began using extensible markup language (XML) in 2014; this language provides the benefit of
using the Internet to allow for the free movement of e-HM shipping paper information.
3.1.2
Maritime Mode
Maritime vessels can carry over 6,000 containers with many HM at a time, and most vessel operators
have developed electronic business systems to manage HM shipping documents. Most international
maritime commerce is currently performed electronically; these vessel operators need to be granted
authority by the U.S. Government to exchange HM information electronically for U.S. shipments. Most
maritime vessel operators have already developed electronic business systems to manage HM shipping
documents, and most international maritime commerce is performed electronically.
Most maritime carriers use EDI as their data exchange language because of their interaction with railroad
carriers. To be able to perform intermodal transfers with rail carriers, and because a regulatory
requirement for e-data does not exist, maritime carriers have been using EDI for e-HM shipping paper
communication. EDI currently has all the HM data elements required by 49 CFR 172 and the
International Maritime Dangerous Goods (IMDG) Code. Using EDI instead of hardcopy shipping papers
for exports would present a business benefit for many maritime carriers.
11
The aircraft operator must ensure the telephone number is monitored at all times the aircraft is in flight. The telephone number is not required
to be placed on the notification of pilot-in-command if the phone number is in a location in the cockpit available and known to the flight crew.
Paperless Hazard Communications Pilot Project
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In June 2014, the United States Coast Guard’s (USCG’s) Cargo and Facilities Division (CG-FAC)
purchased tablets for field units to use in conducting facility safety and security operations. These devices
are authorized to store open source information, Internet releasable, and/or non-USCG sensitive data.
While the current use of the tablets is to make reference materials accessible to examiners, inspectors, and
investigators while conducting field activities without needing to carry volumes of paper copies of
reference materials, the use of such devices may be expanded in the future.12
3.1.3
Rail Mode
The Rail Mode transports HM in box and tank cars; all shipment data is received electronically in EDI
language. Hardcopy HM shipping papers are required to be carried by the train crew for use by
emergency responders in the event of an incident and to meet the existing regulatory requirement.
Also, Section II of the United States Hazardous Materials Instructions for Rail13 document specifies that
no person may accept HM for shipment by rail transportation or transport HM in a train unless a crew
member has the following documents:
Acceptable shipping papers;14
Acceptable emergency response information; and
A paper document that is showing the current position of the HM shipment in the train (i.e., a
consist).
PHMSA and the Federal Railroad Administration (FRA) issued a notice of proposed rulemaking (NPRM)
on August 18, 2011 [76 FR 51324]15 to amend the HMR (49 CFR Parts 171-180) to incorporate
requirements based on seven existing special permits,16 including DOT-SP 7616.17 The special permit,
DOT-SP 7616, authorizes rail carriers granted approval by PHMSA to accept shipping paper information
for HM shipments via telephone (voice communications) and to authorize certification requirements when
transmitted through voice communications or EDI. The Hazardous Materials: Incorporating Rail SPs into
the HMR; Final Rule,18 published in the Federal Register on June 25, 2012, made the following regulatory
changes to the HMR:
49 CFR 172.201(a)(5)—Electronic shipping papers. For transportation by rail, a rail carrier may
accept shipping paper information either telephonically (i.e., voice communications and
facsimiles) or electronically (via EDI) from an offeror of an HM shipment in accordance with the
following provisions:
-
12
When the information applicable to the consignment is provided under this requirement,
the information must be available to the offeror and carrier at all times during transport,
and the carrier must have and maintain a printed copy of this information until delivery of
USCG Memorandum 13480, 30 June 2014, from A.E. Tucci, CAPT COMDT (CG-FAC) to LANT-54, PAC-54.
13 http://boe.aar.com/boe/download/US_HMI.pdf.
“Acceptable shipping papers” must be printed and legible and include railroad-produced documents, customer-produced documents,
connecting carrier documents, hand-printed documents, and HW manifests.
15
under Docket Number PHMSA 2010-0018 (HM-216B)
16
Federal Register Volume 76, No. 160, August 18, 2011 [Docket No. PHMSA-2010-0018 (HM-216B)].
17
http://www.phmsa.dot.gov/pv_obj_cache/pv_obj_id_D59F5CA11D8EE7F6DEDA5032AF33874E709E0100/filename/SP7616_2005120931.pd
f.
18
FR Volume 77, No. 122, June 25, 2012 9 FR Doc. 2012-13960, filed June 22, 2012).
14
Paperless Hazard Communications Pilot Project
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the HM on the shipping paper is complete. When a paper document is produced, the data
must be presented as required by this subpart;
-
The offeror must forward the shipping paper (record) for a loaded movement to the
carrier before shipment unless the carrier prepares the shipping paper on behalf of the
offeror. The offeror is only relieved of the duty to forward the shipping paper once the
offeror has received a copy of the shipping paper from the carrier;
-
A carrier that generates a residue shipping paper using information from the previously
loaded movement of HM packaging must ensure the description of the HM that
accompanies the shipment complies with the offeror's request; and
-
Verification: the carrier and the offeror must have a procedure by which the offeror can
verify the accuracy of the transmitted hazard communication information that will
accompany the shipment.
49 CFR 171.8 defines EDI as the computer-to-computer exchange of business data in standard
formats. In EDI, information is organized according to a specific format (electronic transmission
protocol) agreed upon by the sender and receiver of this information and transmitted through a
computer transaction that requires no human intervention or retyping at either end of the
transmission.
49 CFR 172.202(b) allows shipping descriptions for HM offered or intended for transportation by
rail that contain all the information required in 49 CFR 172.202 and that are formatted and
ordered in accordance with recognized EDI and, to the extent possible, in the order and manner
required by 49 CFR 172.202 are deemed to comply with 49 CFR 172.202(b).
49 CFR 172.204(a)(3) and (d)(3) allow for shipping paper certifications for HM shipments via
rail to be accomplished by one of the following methods:
3.1.4
-
Verbal Certification—When received telephonically, by the carrier reading the complete
shipping description that will accompany the shipment back to the offeror and receiving
verbal acknowledgment that the description is as required. This verbal acknowledgment
must be recorded, either on the shipping document or in a separate record, e.g., the
waybill, by 49 CFR 174.24, and must include the date and name of the person who
provided this information; or
-
Electronic Signature Certification—When transmitted electronically, by completing the
field designated for the shipper's signature, the shipper is also certifying its compliance
with the certification specified in 49 CFR 172.204(a). The name of the principal partner,
officer, or employee of the offeror or their agent must be substituted for the asterisks.
-
When transmitted by telephone or electronically, the signature must be in one of the
following forms: the name of the principal person, partner, officer, or employee of the
offeror or his agent in a computer field defined for that purpose.
Roadway Mode
Transport of HM by roadway carriers is significantly different from their modal counterparts; roadway
vehicles travel shorter distances and thus have more individual transportation trips. Also, many variations
Paperless Hazard Communications Pilot Project
9
exist among roadway carriers: some transport a single commodity along defined transportation routes,
while others pick up and deliver multiple commodities along routes that change based on delivery needs.
The following list provides information from the motor carrier industry regarding HM communications:
The motor carrier industry emphasizes the importance of having an HM paper documentation
trail (for billing purposes, delivery receipts, driver payment records, etc.), and most motor carriers
receive HM manifests and bills of lading in hardcopy.
Some motor carriers have electronic or automatic onboard recording devices and use them for
activities such as tracking drivers’ hours of service and locations; commodity delivery
confirmation; etc. The owner-operators pay the installation costs and a monthly fee for these
devices. The possibility exists for additional capabilities to be added to these devices for
additional costs.
Existing electronic and automatic onboard recording devices do not function in some areas of the
U.S. and Canada with Internet connectivity dead spots; the same issue would likely exist for an eHM communication system.
Motor carriers that transport fuel do not invest in electronic devices, because fuel pick-ups and
deliveries are typically direct and routine shipments, and fuel companies have a lower profit
margin than other carriers.
Some trucking companies either cannot afford to purchase an electronic system or do not see a
business reason to invest in one; the carrier stakeholders recommend PHMSA establish the
performance standard for e-HM communication and keep the existing requirements for hard copy
HM shipping papers.
Implementation of e-HM shipping papers may also be difficult for smaller motor carrier
companies that transport a wide variety of products; that do not have set delivery schedules; or
that make multiple stops on a transport route delivering various HM contained in trailers with
multiple compartments, because of the complexity of these HM shipments.
Motor carriers who do not have onboard technology are concerned that they will be unable to
provide e-HM information directly and readily to inspection and emergency response personnel,
scenarios that could delay shipments; cause loss of revenue for the driver and the carrier, and
potentially contribute to incident liabilities.
An electronic means does not currently exist for the motor carriers to receive HM shipping
documents from, or to send HM shipping documents to, any of the other carrier modes. Roadway
carriers serve a critical function in the HM transportation chain, and provisions for ensuring
continuity of commodity as well as information flow within the roadway carrier stakeholder
group need to be addressed.
3.2 Communications with Federal Agencies and Private
Companies Using E-systems
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Between 2011 and 2014, PHMSA met or participated in teleconferences with the U.S. Federal Aviation
Administration (FAA) its contractor, MITRE, and IATA; the U.S. Department of Defense (DOD) and the
U.S. Transportation Command (USTRANSCOM); the U.S. Department of Energy’s (DOE’s) Oak Ridge
National Laboratory (ORNL) and its contractors, Turnkey Technical Services, LLC (Turnkey), and
URS—CH2M Oak Ridge LLC (UCOR); the U.S. FRA, the Association of American Railroads (AAR),
Operation Respond Institute (ORI), and Watco Companies, LLC (Watco); the U.S. Environmental
Protection Agency (EPA); and the United Parcel Service (UPS) regarding their e-system activities. The
following subsections summarize the information regarding these e-systems.
3.2.1
U.S. Federal Aviation Administration, MITRE, and the International Air
Transport Association E-Initiatives
PHMSA learned about the following Air Mode electronic initiatives during consultation activities
conducted between 2011 and 2014:
FAA and MITRE were developing an electronic initiative called Flight Object (FO) Concept. FO
was conceived to be part of FAA’s next generation concept for electronically collecting about ten
different information types, one of which is HM information. The-HM component of FO was
intended to include data elements currently required by the Shipper’s Declaration for Dangerous
Goods (SDDG) document. In 2011, the FO team was working with IATA, which developed a
data schema for international hazardous cargo messaging systems.
FAA and MITRE reported that FO stakeholder benefits include faster receipt of HM information
for emergency responders and better ability for FAA security personnel to identify and track
hazardous cargo logistics. FAA and MITRE also reported that some shippers are reluctant to
participate in the FO initiative because they already provide the required information in hardcopy;
these shippers do not want to provide electronic information for privacy concerns and other
reasons. FAA and MITRE were trying to develop incentives for such shippers.
IATA’s E-Freight Project that allows for the movement of air cargo via the use of e-data instead
of some hardcopy information. The project operates according to the provisions of the Montreal
Convention, Protocol 4, which eliminated the need for consignors of cargo to complete detailed
air waybills before consigning goods to a carrier, and allowed for consignors to use simplified
electronic records in place of such detailed air waybills.
IATA stated that airlines currently have sophisticated security protocols for other e-records (e.g.,
passenger information), so e-HM should fit in with these existing protocols. Also, because
international air shipments already allow for e-dangerous goods records, IATA believes HMACCESS should be able to leverage these international allowances for e-HM shipping papers.
IATA reported that airlines historically used EDI for inputting cargo booking and related
financial accounting information, as EDI provides a structured message defined for teletype;
however, the airlines were due to move to XML in 2014. IATA reported that XML provides the
benefit of the Internet to allow for the free movement of information. IATA reported it would
facilitate the use of available data standard interfaces to transfer existing EDI data to XML.
IATA explained that an interface needs to be developed for air and road carriers before the
Paperless Hazard Communications Pilot Project
11
Dangerous Goods Manifest can be transmitted electronically; until then, the air carrier einformation needs to be transformed into hard copy when air cargo is transferred to trucks.
3.2.2
U.S. Department of Defense and U.S. Transportation Command E-systems
On January 17, 2012, PHMSA met with DOD USTRANSCOM’s Defense Transportation Electronic
Business (DTEB) Committee to learn about DTEB’s implementation of the American National Standards
Institute (ANSI) EDI standards (ANSI X12) for use within DOD transportation.
DOD is a very large military entity that transports HM both domestically and internationally. DOD’s
system supports single mode and intermodal transfers. The DTEB Committee is a volunteer consensusbased group with input from the military services, Defense Logistics Agency (DLA), Defense Finance
and Accounting Services (DFAS), General Services Administration (GSA), and USTRANSCOM. The
DTEB committee provides a forum where the defense transportation activities can coordinate the
development and implementation of their e-business projects. The DTEB Committee also works on
establishing EDI standards for transportation processes throughout DOD that follows the ANSI X12
schema. USTRANSCOM chairs the DTEB committee.
USTRANSCOM does not have one e-HM system; rather, the DTEB Committee works to ensure that the
various e-HM systems are compliant with the X12 standards. USTRANSCOM is responsible for
transportation-related processes in DOD; DLA has oversight of DOD’s supply side (warehouse).
USTRANSCOM primarily uses legacy EDI systems; DLA uses EDI as well as other legacy systems (e.g.,
flat file). These stovepiped systems communicate via “translators;” i.e., software that provides the
interface between internal systems and the EDI format sent/received. USTRANSCOM uses the X12
standards as a base for its data elements, and then adds information to them to customize for its systems.
Shippers, carriers, and governmental officials can utilize these systems directly, and emergency
responders can call upon a particular process to access needed HM data. Access to the data is vetted by
third-party logistics companies or the material owner.
The USTRANSCOM staff shared the following challenges19 related to e-HM:
System integration can be difficult;
Data translation can introduce data integrity-related issues;
XML, by its very nature of being extensible, at times may not work well with standardization
(e.g., the X12 standards or similar protocols);
Sometimes translators act as a crutch, because they can discourage organizations from developing
new standard systems, thus causing functional requirements “creep”; and
The current requirement in 49 CFR 172, Part C for a signature on the certification section of the
shipping paper will be difficult to address on an e-HM document without a regulatory
change/exemption.
19
According to USTRANSCOM staff, while the X12-based codes are known in the transportation community, the emergency response
community may not be familiar with them.
Paperless Hazard Communications Pilot Project
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The USTRANSCOM staff shared the following benefits of related to e-HM over a paper-based system:
Reduced time required for data exchange;
Near to instant gratification in obtaining data;
Date is editable and able to be validated;
Data is more storable; and
Data is often more acceptable to other systems/the e-environment.
The USTRANSCOM staff shared the following “lessons learned” related to developing an e-HM:
Establish a process;
Use standardized data;
Use equipment and software with the capability to be modernized;
Wherever possible, conform to what is already in place; and
Be aware that pushing in/pulling out data are different activities that require distinct processes.
3.2.3
U.S. Department of Energy E-System
On January 18-19, 2012, PHMSA met with staff from DOE’s ORNL and its contractors Turnkey and
UCOR20 at the Oak Ridge Reservation in Tennessee, a research and manufacturing complex established in
the early 1940s to produce enriched uranium for the World War II Manhattan Project. A private road on
the property connects multiple Oak Ridge operations that deal with all nine HM classes.
Turnkey is a small business in Oak Ridge that supports DOE’s Oak Ridge HM operations. The company
has developed an e-system, the Radio Frequency Identification Transportation System (RITIS), in
partnership with DOE. RITIS came online in March 2009. It uses a passive radio frequency identification
(RFID) system composed of interrogators (i.e., readers) and tags (i.e., labels) to integrate HW operations,
transportation logistics, and information technology, and is currently being used for tracking HM
transported on the Oak Ridge Reservation. RITIS uses commercial off the shelf (COTS) hardware and
software and supports multiple open-source technologies. Information is backed up on two databases
simultaneously, allowing for fail-safe operation.
RITIS equipment includes handheld devices, weigh scales, servers (applications and data), web browsers,
and RFID external towers (readers). Each truck has a tag (non-battery) enclosed in a hard case; this nonbattery, passive tag option was selected when the system was created to provide an “intrinsically safe”
RITIS. A uniform resource locator (URL) is assigned to all codes that point to tracking information. Date
and time information is added to the URL and also tracked. The information goes to “the Cloud,” and
shippers, drivers, and other vetted personnel can update the Cloud information based on the URL.
“Mashups,” combinations of data from two different fields, are allowed. Because Wi-Fi is not allowed in
classified Oak Ridge Reservation areas, the data is written to the tag; once the vehicle passes a portal, the
data is uploaded from the tag to the system, and the official internal activity record begins.
20
UCOR is DOE’s cleanup contractor for the Oak Ridge Reservation.
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The DOE, their contractors (Oak Ridge), UCOR, and Turnkey staff have access to RITIS. RITIS is also
loaded with acceptable parameters, which reduces the chance for input errors and quickly highlight any
data anomalies or errors. Checks on the RITIS occur multiple times each day, and data can be accessed
24/7.
In a 2011 test of RFITS’s efficiency, Turnkey staff found that, for each truck transporting HW, the RFITS
reduced eight pieces of paper information to zero. As reported in October 2011, more than 25 DOE Oak
Ridge projects totaling almost 55,000 e-shipments have shipped via the RITIS Program, with a
corresponding cost savings of more than $16 million.21 Turnkey reported that approximately 1.5 full-time
equivalent (FTE)/year in labor are required to maintain RITIS. As of the beginning of 2012,
approximately $1M had been spent on RITIS (hardware, labor); $300K of this cost was associated with
initial one-time setup fees. Annual operation and maintenance costs (including labor) are approximately
$250K.
DOE/Turkey staff shared the following “lessons learned” perspectives for developing an e-system:
21
Prefer COTS systems and open source architecture over proprietary systems and closed
architecture;
Design infrastructure that can change/grow with the business;
Develop an e-system that is open, modular, and expandable (allows for integration of new
technology into system);
Use a variety of vendors;
Define all the business rules at the beginning, and ensure that all affected staff are involved;
Project business development out one, five, and ten years, and ensure the system is robust and
diverse to support the business plan;
Source: Nuclear Decommissioning Report, October 2011, Issue 6, Volume 1; “RFITS Takes Shipping to the Next Level.”
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Make the system framework as simple as possible, thereby eliminating barriers and allowing
more entities to participate in e-HM;
Encourage the public/stakeholders to freely give data, with the e-system owner responsible for
providing security/anonymity;
Make the design modular, allowing services to be added later and identifying data meeting points;
Require authentication information whenever a person attempts to access any data; and
Consider the space needed for data storage and the resolution and battery life of e-system
handheld devices during the design phase.
Turnkey staff shared the following considerations for any e-system:
Determine where the minimum needed information resides (at the base company level, with the
shipper, etc.);
Determine how the minimum information can be provided to emergency responders/inspection
personnel in a timely manner (via cellular, radio, computer, other);
Remember the HM information should travel with the conveyance transporting it; and
Consider technology on the vehicle vs. information residing at the office.
DOE/Turnkey staff listed the following benefits of using the e-system RFITS over a paper-based system:
Reduced time required for data exchange;
Increased data quality;
Integration of operations reduced overall cost of data collection activities;
Fixed costs of monitoring performance and predicting supply and demand;
Increase in driver output without increasing labor (32 manual HM shipments vs. 139 e-shipments
in an eight-hour shift); and
Reduced greenhouse gas emissions (trucks no longer left idling during paperwork completion and
security inspections).
DOE/Turnkey staff also expressed a preference for XML over EDI, citing XML’s flexibility and
readability by both humans and machines as benefits over EDI’s expensive legacy language.
DOE staff shared information about its contract with FedEx, which manages all of DOE’s continental
U.S. radioactive isotope air shipments (approximately 2% of DOE’s total HM). DOE has its own shipping
manifest form (“ATMS”), but FedEx wants DOE to use its form. FedEx instructs DOE to “EDI the DOE
ATMS to FedEx;” once this action is complete, FedEx does not allow DOE to then have a copy of the
FedEx manifest. This real scenario presents one example of the complexities associated with data security
and ownership.
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3.2.4
U.S. Federal Railroad Administration, Association of American Railroads, and
Affiliates E-HM Emergency Responder Communication Initiatives
In the Summer 2012, PHMSA participated in a teleconference with FRA, AAR, ORI, and Watco22 to
discuss work these organizations were performing to comply with National Transportation Safety Board
(NTSB) recommendation R-07-2, which calls for FRA23 to “assist PHMSA in developing regulations to
require that railroads immediately provide to emergency responders accurate, real-time information
regarding the identity and location of all HM on a train.” The NTSB recommendation is provided for
reference in Appendix E: NTSB Recommendation R-07-2.
ORI is a not-for-profit company that developed the Operation Respond Emergency Information System
(OREIS™), a software program made available only to emergency response organizations. The system
offers response guidance for dealing with specific chemicals under varying conditions, contains other
responder resource information, and has a wireless version called OREIS™ Mobile. Through OREIS™,
vetted emergency responders can directly access a rail carrier’s files (via an identification and password
application) to identify whether HM are being transported on a specific railcar; if HM are present,
OREIS™ provides a verification of the contents and initial guidance as to the appropriate response.
Challenges associated with OREIS™ for emergency responders include the following:
To learn information about multiple cars involved in a derailment, each car must be researched
individually via OREIS, which can be inefficient for large derailments; and
OREIS does not have information regarding the location of the car in the train (i.e., OREIS lacks
consist information).
As of Spring 2015, CSX Class I Railroad was completing the test phase of its “Operation Respond”
mobile emergency information system, a collaborative product from CXS and ORI. The system has been
designed to provide emergency responders with mobile access (via iPhone, Android devices and most
browsers) to information regarding HM traveling on CSX rails. In the event of a rail emergency, CSX
Operation Respond quickly locates and identifies the contents of rail cars carrying HM. Through the app,
responders can securely access:
Real-time information on the contents of rail cars;
Real-time complete train list information; and
Other useful emergency response information designed to assist in responding to a rail-related
transportation emergency.24
22
Watco is an international transportation company based in Kansas offering a variety of rail, container-shipping, intermodal, and trucking
services. Watco operates 27 shortline railroads (small or mid-sized Class II and Class III railroad companies which operate over short distances)
in the U.S. and Australia, is one of the largest U.S. shortline railroad companies, and operates several transloading railcar facilities.
23
FRA is responsible for promulgating and enforcing rail safety regulations and conducting research and development in support of improved
railroad safety and national rail transportation policy. (www.fra.dot.gov)
24
http://www.beyondourrails.org/safety/respond
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FRA reported in September 2015 that all Class 1 railroads use systems similar to OREIS™ for providing
emergency responders with mobile access to information on HM travelling by rail. FRA reported that,
while these systems make access to HM information easier for emergency responders, they do not provide
updated, accurate consist information in scenarios where a derailment or other incident occurs after cars
are added or removed from the train but before the train moving to an automatic equipment identification
(AEI) reader.25 In these scenarios, the train consist available at the railroad headquarters and on the train
(if available and intact after the incident) will only account for the consist that was in place when the train
passed the last AEI reader.
3.2.5
U.S. Environmental Protection Agency E-Manifest System
PHMSA had an initial teleconference with EPA in late Summer 2012 to discuss the process the EPA
followed to determine the need for, and draft regulations pertaining to, the use of electronic HW manifests
(e-manifests) in lieu of hardcopy manifests for tracking the generation, treatment, storage, and disposal of
HW. The EPA’s E-Manifest System has evolved from a 2001 decentralized system concept to an actual
system via legislation signed into law on October 5, 2012 directing EPA to establish and implement a
single, national, vendor-developed system for e-manifest information, with users paying fees to use the EManifest System. The E-Manifest System must be fully established and operational by October 5, 2015
for use by any user. PHMSA and EPA communicated regularly regarding the status of both projects
between 2012 and 2015. Such changes to the HW regulations may necessitate an HMR revision allowing
an e-manifest to be an acceptable shipping paper.
More information on the current status of EPA’s e-manifest system is provided in Appendix G:
Information on EPA’s E-Manifest System.
3.2.6
United Parcel Service E-HM Communication
In a discussion with PHMSA during Summer 2012, UPS employees indicated that the biggest challenge
to successful e-HM shipping paper implementation will be changing perceptions of HM stakeholders
(shippers, carriers, emergency responders, and law enforcement personnel) regarding the ease and
benefits of using e-HM shipping papers versus hardcopy documents.
In January 2014, UPS and PHMSA began coordinating outreach efforts to educate and inform first
responders and inspectors about the changes in HM communications document accessibility for UPS
feeder trucks. With the new procedure, when an inspector or emergency responder requires HM shipping
papers, drivers will provide a toll-free number to call for access to documents containing a manifest of
any HM contained in the shipment. This new process will streamline the sharing of information with
inspectors and first responders.26 PHMSA authorized UPS to begin transmitting HM shipping paper
information electronically, by phone, or fax as of June 1, 2014, via, Hazardous Materials SP 15747. This
authorization applies only to UPS small package tractor-trailer operations, the movement of small
package shipments between UPS facilities, and deliveries by tractor-trailer; UPS Freight and all other
25
AEI readers are trackside-mounted devices that are part of an electronic recognition system using radio frequency technology to communicate
train information, including consist information, with passive tags mounted on railcars and locomotives (www.aar.org).
26
http://www.pahazmat.com/news/ups-article/
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UPS operations will continue to carry hardcopy HM shipping papers. This UPS SP (DOT-SP 15747) was
updated on May 13, 2015 (fifth revision); refer to Appendix H: UPS Special Permit 15747.
Since June 1, 2014, the UPS Call Center has been contacted 143 times under the provisions of DOT-SP
15747, and there have been zero instances where the caller has been unable to receive the required
information. One of the calls took longer than five minutes to transmit the information; however, the
average length of time for the information to be transmitted is approximately 2 minutes and 30 seconds.
The one call more than five minutes was caused by issues with Adobe Reader on the receiver’s end of the
transmission. Thirteen calls were emergency situations including six trailer fires and four rollovers; the
type of emergency was not detailed for the other three calls. During the emergency situations, it was
found that first responders benefitted from obtaining the shipping paper information while staying a
distance away from the vehicle.27
3.3 Discussions with HM Shippers, Carriers, Law Enforcement
Inspectors, and Emergency Responders
Information in this section was provided to PHMSA during 2012-2015 stakeholder discussions and at the
four stakeholder workshops for shippers, carriers, law enforcement inspectors, and emergency responders
PHMSA hosted in September 2012. The workshops’ objectives were to:
Share with participants stakeholder information provided to PHMSA to-date;
Obtain further information and feedback from workshop participants as they relate to facilitating
e-HM communication; and
Prepare white papers28 to document feedback, opinions, concerns, gaps, and vulnerabilities from
both prior stakeholder consultation efforts and workshop participant discussions.
3.3.1
Discussions with HM Shippers
The HM shipper industry includes a wide variety of chemical companies and manufacturers that make
and/or ship materials such as oil and natural gas; chlorine gas and solutions; compressed and liquefied
gases; specialty gases; explosives; and various other chemicals. Many of these chemicals are listed as HM
under 49 CFR Part 172 and other regulatory guidance documents. The 49 CFR 172.200(a) states, “each
person who offers a hazardous material for transportation shall describe the hazardous material on the
shipping paper in the manner required by 49 CFR Part 172, Subpart C—Shipping Papers.” Thus, all HM
shippers are required to prepare and provide hardcopy HM shipping papers for HM that are in
transportation, in accordance with 49 CFR Part 172.
27 Information on the effectiveness of DOT-SP 15747 is current as of July 31, 2015.
28
The two white papers summarizing the information obtained during the September 2012 workshops are provided on PHMSA’s HM-ACCESS
website: http://phmsa.dot.gov/hazmat/hm-access/stakeholder-information-papers. These papers highlight the collective HM transportation
community’s priorities, gaps, and concerns for implementing paperless hazard communications.
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In the Summer of 2012, PHMSA participated in teleconferences with the following HM shipper
associations, organizations, and private companies:
American Chemistry Council (ACC)
American Petroleum Institute (API)
Compressed Gas Association (CGA)
Council on Safe Transportation of Hazardous Materials, Inc. (COSTHA)
Institute of Makers of Explosives (IME)
The Chlorine Institute (CI)
Magellan Midstream Partners, L.P.
Procter & Gamble
United Parcel Service (UPS)
3.3.1.1
Shipper Feedback on E-systems
Some HM shipping companies have e-systems that are used for business purposes (driver payment, HM
invoices, etc.). These systems have some/all of the HM information fields currently required on the HM
shipping paper. The majority of these companies print shipping papers by pulling information from these
e-systems. Also, many companies that already have e-systems containing HM shipping information
should be able to transition easily to an e-HM shipping paper.
3.3.1.2
Shipper-Specific Concerns, Gaps, and Vulnerabilities with E-communication
Shippers provided the following thoughts on e-communication:
E-HM should be performance-based, and allow for e-HM communication flexibility.
E-HM implementation should not make compliance requirements more complicated.
Companies currently capable of performing e-HM communication have developed these
capabilities for business reasons. If the government requires e-HM, some companies would be at
a disadvantage because of the costs associated with implementation.
Business purposes drive technology; innovation will be hindered, lost, or stifled if the
government requires a particular technology be used to satisfy e-HM.
The development of a shipper/HM industry e-HM system may not be helpful or useful to
emergency responders and law enforcement, and vice versa.
The capability of emergency responders to receive/access the e-HM information in certain
situations (e.g., coverage issues in rural and geographically challenged areas; availability of
technology; current operating procedures, etc.) may be compromised.
The potential for data errors and omissions exists (for both e-communication and current
hardcopy format).
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3.3.2
Discussions with HM Carriers
The carrier industry includes companies that transport all types of HM in various quantities (bulk and
non-bulk) in assorted containers and other packagings in all modes on different types of vehicles,
including vessels, planes, trailers, trucks, and railcars. Some carriers transport HM intramodal others
transport HM both intra- and inter- modal. A shipping paper, prepared by the HM offeror (shipper), is
required for the transportation of the HM. HM carriers are required to maintain the HM shipping paper
when the HM is in transportation and for a certain period after delivery is completed. Shippers must
create a Dangerous Goods Manifest for each HM transported internationally in addition to the HM
shipping paper requirements identified in 49 CFR 172 for U.S. HM shipments.
In the Summer of 2012, PHMSA participated in teleconferences with the following HM carrier
associations, organizations, and private companies:
International Air Transport Association (IATA)
APL Limited (APL)
Hapag-Lloyd America
Hyundai American Shipping Agency
International Vessel Operators Dangerous Goods Association (IVODGA)
American Trucking Associations (ATA)
National Tank Truck Carriers (NTTC)
Owner-Operator Independent Drivers Association (OOIDA)
3.3.2.1
Carrier Opinions and Feedback—All Modes
Carriers provided the following feedback regarding e-HM communication:
Because of the wide variation among modal carriers, means for e-HM communication will vary
by carrier and by mode.
Accuracy and completeness are the two most important e-HM information requirements for
carriers.
Allowing rather than mandating the use of e-HM information would be accepted among the
carrier industry.
The Air Mode currently has sophisticated security protocols for other e-records, and international
air shipments already allow for e-dangerous goods records.
The Rail Mode transports HM in box and tank cars; all HM shipment data is received
electronically in EDI format.
Most maritime vessel operators have already developed electronic business systems to manage
HM shipping documents, and most international maritime commerce is performed electronically.
Most maritime and air carriers use EDI because of their interaction with railroad carriers.
Roadway HM carriers always receive HM manifests and bills of lading in hardcopy.
Some motor carriers have electronic or automatic onboard recording devices. Additional
capabilities may be able to be added to these devices for additional costs.
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E-HM communication should be easy to implement for motor carriers who deliver a single HM
or who always deliver the same HM to the same locations.
An e-HM system may provide a dual benefit for motor carriers who load HM from multiple sites,
as it could help the driver determine HM compatibilities and segregation requirements before
loading the HM.
3.3.2.2
Carrier-Specific Concerns, Gaps, and Vulnerabilities with E-communication—
All Modes
Modal carriers shared the following common concerns regarding e-communication:
Carriers want the Federal government to ensure that e-HM communication is allowed rather than
mandated.
Carriers are concerned about security and business-related issues once e-HM communication is
conducted outside of a controlled environment.
Carriers see a difference in the need for electronic information for business purposes and the need
for information that accompanies HM shipments for emergency response purposes.
HM technical names can be difficult for carriers to determine, and trade names are currently not
authorized for use by 49 CFR 172.
An electronic means does not exist for motor carriers to receive HM shipping documents from, or
to send HM shipping documents to, carriers in other modes.
3.3.2.3
Specific Concerns, Gaps, and Vulnerabilities with E-communication—Roadway
Carriers
Roadway carriers shared the following concerns regarding e-communication:
The motor carrier industry emphasizes the importance of having an HM paper documentation
trail (for billing purposes, delivery receipts, driver payment records, etc.), and most motor carriers
receive HM manifests and bills of lading in hardcopy.
Some trucking companies either cannot afford to purchase an electronic system or do not see a
business reason to invest in one.
They recommend PHMSA establish a performance standard for e-HM communication and keep
existing requirements for hardcopy HM shipping papers.
Implementation of e-HM shipping papers may be difficult for small motor carriers.
Existing electronic onboard recording devices do not function in areas with Internet connectivity
dead spots; the same issue would likely exist for an e-system.
Motor carriers who do not have onboard technology are concerned that they will be unable to
provide e-HM information to inspectors and emergency responders.
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3.3.2.4
Specific Concerns, Gaps, and Vulnerabilities with E-communication—Air and
Maritime Carriers
Air and maritime carriers shared the following concerns regarding e-communication:
Air and maritime carriers have been using EDI to perform intermodal transfers with rail carriers,
and require e-HM shipping paper data be provided to them in EDI format.
EDI elements may be different between individual carriers.
Each of the four major Class I rail carriers has different EDI requirements for rail billing.
EDI is not organized as a required sequence of information or fields, and data standardization is
an issue, as is how and the order in which emergency response information is presented.
Paperwork for imports is often missing information and often contains incorrect data; these issues
provide additional challenges for verifying data accuracy provided in import EDI systems.
Different requirements of e-HM communication information for domestic and international HM
shipments may need to be developed.
The airlines historically used EDI for inputting cargo booking and financial accounting
information, but the industry may be moving to XML.
Some rail carriers insist each HM shipment have a Standard Transportation Commodity Code
(STCC)29 before the rail’s acceptance of the HM from intermodal carriers.
3.3.3
Discussions with HM Law Enforcement Inspectors
The HM law enforcement community consists of trained HM inspectors who are organized by
transportation mode. Regardless of mode, all HM inspectors will request a copy of the HM shipping
papers as part of the inspection process.
3.3.3.1
Air Mode Inspector Feedback and Opinions
Discussions with FAA employees during 2013-2015 revealed that, per 49 CFR 175.30(a)(2) and (b),
aircraft operations personnel are required to inspect HM shipments to ensure that HM accepted aboard an
aircraft for transportation are “described and certified on a shipping paper prepared in duplicate in
accordance with 49 CFR Part 172,” and that aircraft operators inspect all HM in packages, outside
containers, and overpacks immediately before placing them aboard an aircraft or in a unit load device or
on a pallet prior to loading aboard an aircraft.
The FAA HM inspectors also conduct after-shipment inspections at shipper facilities and airport carrier
locations. They review HM shipping papers (required to be maintained by aircraft operators in hardcopy
or via electronic image at or through its principal place of business per 49 CFR 175.33(c) for one year
after the material is accepted by the initial carrier) and NOPICs (required to be maintained by aircraft
operators in hardcopy or via electronic image at or through its principal place of business per 49 CFR
175.33(c) for 90 days at the airport of departure or the operator's principal place of business) to determine
29
The STCC is a rail publication containing specific product information used on waybills and other shipping documents, is now being used by
rail carriers for HM transport. According to Maritime and Air Mode carriers, STCC codes are not specific to a particular material; are not used or
understood internationally; and have no use for emergency response purposes.
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compliance with the HMR.
3.3.3.2
Maritime Mode Inspector Feedback and Opinions
PHMSA held teleconferences with USCG inspectors from the following sectors during the Summer of
2012:
Sector Baltimore (Maryland)
Sector Boston (Massachusetts)
Sector Houston-Galveston (Texas)
Sector Juneau (Alaska)
Sector Los Angeles/Long Beach (California)
Sector Portland (Oregon)
These sectors explained that port container inspections are conducted by USCG inspectors; enforcement
personnel inspect samples of declared HM containers randomly (i.e., containers with manifests
identifying HM as contained in them). Container inspections are usually announced and planned in
advance. Typically, USCG inspectors at small and medium ports receive hardcopy HM shipping papers
from the terminal/yard office; at the large ports, they request shipping papers from the shipper via email
or telephone. The shipping papers are usually provided to them, via email or facsimile, 20 minutes to 48
hours after the request is made.
The USCG Inspectors shared the following regarding e-systems:
Electronic shipping papers would be more convenient but are not a necessity for inspectors at
small and most medium container ports.
Because shipping papers requested by inspectors at some medium and most large container ports
can result in a 48-hour wait time, an e-system that could provide the shipping papers quicker
would add convenience and reduce inspector wait time.
An e-HM system that provides the information directly to inspectors would streamline the
shipping paper request process and shorten the container inspection selection time for inspectors
at many large container ports.
The USCG inspectors shared the following concerns over information gaps and vulnerabilities:
Allowing shippers a choice between hardcopy and electronic shipping papers may lead to
confusion as to where and how inspectors can obtain the documents.
Altering a process for inspectors at small and medium container ports that already fits their needs.
Ports that transmit shipping paper information between yard and USCG offices could experience
an unnecessary duplication of information.
If the system crashes, electronic information could be lost or unavailable.
Some of the remote ports do not have wireless capability.
Electronic shipping papers may present data entry errors and inaccuracies.
The U.S. cannot regulate the use of electronic shipping papers internationally.
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3.3.3.3
Rail Mode Inspector Feedback and Opinions
The Rail Mode has very specific inspection procedures for HM shipments on railcars; these procedures
are detailed in United States Hazardous Materials Instructions for Rail, Section III.30 Important policy
excerpts from this document are as follows:
All loaded and residue/empty hazardous material shipments must be visually inspected before
accepting them from the shipper; when receiving them in interchange; when placing them in a
train; and at other points where an inspection is required (e.g., 1,000-mile inspection) for the
following conditions/items:
-
Leakage;
-
Required placards and markings;
-
Secure fastening of closures; and
-
Signs of tampering.
If an indication of tampering or a foreign object is found, rail personnel are instructed to take the
following actions:
-
Do not accept or move the rail car.
-
Immediately move yourself and others to a safe location away from the rail car before
using radios and cell phones to make notifications.
-
For cars at a customer's facility, immediately contact local plant personnel. If local plant
personnel are not available or cannot explain what you see, immediately contact the train
dispatcher.
-
For cars on interchange tracks or in the yard, immediately contact the yardmaster or train
dispatcher.
If an HM shipment does not appear to be prepared for transportation, rail personnel are instructed
to:
-
Not accept/pull the HM shipment or allow it to continue in transportation; and
-
Notify the customer, train dispatcher, yardmaster, or immediate supervisor of the
problem.
In addition, Section II of the document specifies that no person may accept HM for shipment by rail
transportation or transport HM in a train unless a crew member has the following documents:
Acceptable shipping papers;31
Acceptable emergency response information; and
A paper document showing the current position of the HM shipment in the train (i.e., train
consist).
30
http://boe.aar.com/boe/download/US_HMI.pdf.
“Acceptable shipping papers” must be printed and legible and include railroad-produced documents, customer-produced documents,
connecting carrier documents, hand-printed documents, and HW manifests. Refer to United States Hazardous Materials Instructions for Rail,
Section II.2 (http://boe.aar.com/boe/download/US_HMI.pdf) for more information.
31
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3.3.3.4
Roadway Mode Inspector Feedback and Opinions
PHMSA held teleconferences with the following HM roadway law enforcement agencies and
organizations during the Summer of 2012 and in 2015:
Federal Motor Carrier Safety Administration (FMCSA);
Commercial Vehicle Safety Alliance (CVSA); and
Idaho State Police.
These agencies and organizations explained that inspections on motor vehicles transporting HM are
usually on demand; i.e., triggered by a particular scenario (such as a traffic violation or routine roadside
inspection) that causes an inspector (a police officer or trained civilian) to select a vehicle for inspection.
Motor carrier inspectors [usually Federal or State Motor Carrier Safety Assistance Program (MCSAP)
Officers] ask the driver for the HM shipping papers at the time of the inspection.
If the driver of a motor vehicle transporting HM cannot produce the HM shipping papers for the
inspector, he/she is cited and receives a violation; the shipping papers must be produced before the
vehicle is allowed to proceed on its journey.
Motor carrier inspectors provided the following information regarding e-HM documentation in the motor
carrier law enforcement arena:
An e-HM system that allows inspectors to view the shipping paper information as one record
instantaneously during the actual inspection (such as on a tablet provided by the driver) would be
acceptable to most inspectors.
FMCSA motor carrier law enforcement inspectors have laptop computers. They enter inspection
data (including HM information) electronically into Aspen, a field system laptop application that
collects all the commercial driver/vehicle roadside inspection details. Aspen utilizes several other
applications that pull data from remote sources. Aspen also includes communication features to
electronically transfer inspection details to SAFER32 and/or SAFETYNET.33 The Aspen data feeds
into FMCSA’s Motor Carrier Management Information System (MCMIS34), a source for FMCSA
inspection, crash, compliance review, safety audit, and registration data that is used in FMCSA’s
Compliance, Safety, and Accountability (CSA) Program.
FMCSA inspectors also use other field system laptop applications, including CAPRI,35 used for
preparing investigations, as well as some safety audits, specialized cargo tank facility reviews,
and HM shipper reviews, and HMPIP,36 a browser-based application used during dock and vehicle
inspections to record compliance problems with hazardous material packages.
32
SAFER, or Safety and Fitness Electronic Records, is a website that displays carrier information available to the public, a store and forward
mailbox system, secondary databases, and communication links. See http://safer.fmcsa.dot.gov/.
33
SAFETYNET is an Oracle based client-server application operated at state safety agencies and Federal divisions that runs on MS Windows
servers as a database management system and allows entry, access, analysis, and reporting of data from driver/vehicle inspections, crashes,
compliance reviews, assignments, and complaints.
34
http://www.fmcsa.dot.gov/mission/information-systems/information-systems#sthash.zqB3mIk6.dpuf.
35
Compliance Analysis and Performance Review Information.
36
Hazardous Materials Package Inspection Program.
Paperless Hazard Communications Pilot Project
25
FMCSA has a portal37 providing single sign-on access to many of its databases (MCMIS, SAFER,
and others). This portal provides access for companies to view their data directly, in real-time or
near-real-time. The ultimate goal of FMCSA is to use the portal to implement an information
technology (IT) solution that improves FMCSA's ability to save lives and improves the safety of
commercial motor vehicles.
Motor carrier law enforcement inspectors prefer a performance standard to a technological
system.
The motor carrier inspection community shared the following concerns regarding information gaps, and
vulnerabilities:
Inspectors in rural or geographically-challenged areas may have Internet connectivity issues; and
Inspectors must be given a copy of the shipping paper for documenting inconsistencies between
the shipping paper information and the HM onboard a vehicle.
3.3.4
Discussions with Emergency Responders
The emergency responder stakeholder group includes public service answering points (PSAPs),
firefighting officials, emergency medical service (EMS) providers, and private companies that provide
emergency response-related services and information for HM incidents. These emergency response
professionals are the first to be notified of, and respond to, incidents involving HM.
In Spring and Summer 2012, PHMSA interviewed personnel from the following emergency response
organizations:
37
International Association of Fire Chiefs (IAFC);
International Association of Fire Fighters (IAFF);
National Fire Protection Agency (NFPA) 472 Committee;
National Volunteer Fire Council (NVFC);
North American Fire Training Directors (NAFTD);
Association of Public-Safety Communications Officials (APCO) International;
Alexandria, Virginia PSAP;
Bell County, Texas 9-1-1 District;
Dane County, Wisconsin Public Safety Communications Center;
Fairfax County, Virginia 9-1-1;
Fairfax County, Virginia Fire and Rescue Department, HM Response Team;
James City County 9-1-1 Emergency Communications (Toano, Virginia);
Laramie, Wyoming Police Department;
Richmond, Virginia PSAP;
Richmond, Virginia HM Response Team;
St. Tammany Parish Communications District (Covington, Louisiana);
Steuben County, New York 9-1-1 Center;
https://portal.fmcsa.dot.gov/login.
Paperless Hazard Communications Pilot Project
26
York, Poquoson, Williamsburg Regional Emergency Communications Center (York County,
Virginia); and
CHEMTREC.
Emergency Responders’ Feedback and Opinions
3.3.4.1
Regarding their specific organizational capabilities and needs, PSAPs and emergency responders
provided the following information:
PSAP personnel training and professional experiences regarding HM vary greatly. Most PSAP
personnel are not familiar with the look and content of an HM shipping paper, and those at small
rural PSAPs may not know about placarding information.
Specific HM information is needed immediately by PSAP dispatchers and first responders; this
information is the “minimum information” initially needed to determine necessary response
actions:
-
PSAP dispatchers initially ask callers for a variety of situational information, including:
o
o
-
The incident location;
Incident and logistical/environmental/sensory details (e.g., “what’s the
emergency,” what’s happening around you,” “what do you smell/hear/see,” etc.);
o Placard information on vehicle;
o Name and quantity of products, including HM, involved in the incident;
o Manifest information;
o Caller’s callback number;
o Driver’s name and contact information; and
o Truck and trailer information (e.g., number) and condition.
On-scene first responders need, or prefer to have, the following HM information
immediately:
o
o
o
o
o
o
o
o
o
o
o
o
Basic description of the HM (boiling point, density, specific gravity, etc.);
Technical and proper shipping name of the HM;
Immediate hazards to health (threshold limit value and immediately dangerous to
life and health information);
Risks of fire or explosion;
Immediate precautions to be taken in the event of an accident or incident;
Immediate methods for handling fires, spills, or leaks;
Preliminary first aid measures;
UN identification number;
Hazard class or division number;
Packing Group;
Emergency contact telephone number; and
The truck and trailer numbers.
Paperless Hazard Communications Pilot Project
27
The PSAPs and emergency responders shared the following information regarding e-HM communication:
Specific HM information is needed immediately;
E-HM communication needs to be scalable;
It is important to have layered and redundant systems;
Accurate information is preferred over quick unverified information;
Pulling”, rather than “pushing,” information is preferred;
E-HM information needs to have the capability to be sent to an Internet protocol (IP) address;
Create and mandate standard format and fields for e-HM information; and
HM trade names are important, and would be useful to add as a required shipping paper field.
3.3.4.2
Emergency Responder-Specific Concerns, Gaps, and Vulnerabilities with Ecommunication
Emergency responders shared the following information regarding e-communication concerns, gaps, and
vulnerabilities:
Limited Internet connectivity access exists in some rural areas;
First responder capabilities regarding access to electronic information vary;
Responder community is lacking training on the use of available electronic tools for e-HM
communication;
It is difficult to obtain information on complex HM shipments (e.g., mixed and less than
truckload (LTL) shipments) in an e-HM system;
A link between the conveyance and the e-HM shipping papers is needed; and
Existing challenges associated with current HM product and shipping paper information need to
be addressed.
3.3.4.3
Emergency Responders Views Regarding Challenges with Current HM Product
and Shipping Paper Information:
Emergency responders shared the following information regarding their views of challenges with current
HM product and shipping paper information:
A “many-to-one” relationship between trade names and proper shipping name exists.
Products with the same proper shipping name may have different response requirements.
MSDS data is rarely titled and/or indexed by proper shipping name or technical name.
Trade name information may not be transmitted, retained, mapped, and/or captured in the transfer
of EDI data across networks.
Trade name information may not be readily apparent to responder or caller even if it is shown on
the shipping documents.
Shipping documents are often complex, and the lack of a standardized form and field layout adds
confusion. Because most callers who place emergency calls are not familiar with shipping
Paperless Hazard Communications Pilot Project
28
documents and HM information, many are confused about providing the requested information to
emergency responders.
Better information on defining and distinguishing the shipper and the carrier is needed.
Having too much information is almost as bad as having too little.
3.3.4.4
Discussions with CHEMTREC, a Private Nationwide U.S. Emergency Response
Company
CHEMTREC was established in 1971 by the chemical industry as a public service hotline for emergency
responders to obtain information and assistance for emergency incidents involving chemicals and HM.
Registration with CHEMTREC authorizes HM shippers the right to portray the CHEMTREC phone
number(s) on their shipping documents, Safety Data Sheets (SDSs), and hazard communications labels.
The portrayal of the CHEMTREC telephone numbers(s) helps registrants comply with regulations such as
49 CFR Part 172.604, which requires HM shippers to provide a 24-hour emergency telephone number on
shipping documents for use in emergency events involving HM. Additional resources provided by
CHEMTREC include:
A round-the-clock communications center staffed by trained and experienced emergency service
specialists;
Immediate access to thousands of chemical product specialists and HM experts through
CHEMTREC’s database of over 30,000 manufacturers, shippers, carriers, public organizations,
and private resources;
A state-of-the-art telecommunications system that supports the virtual emergency response team,
seamlessly linking on-scene responders with chemical experts, transportation companies, and
medical experts;
An expansive electronic library of over 5 million SDSs;
A database of medical experts and chemical toxicologists who provide advice and emergency
medical treatment assistance to on-scene medical professionals treating victims of product
exposure; and
Interpretation capabilities for more than 180 languages in the event of an emergency involving
non-English speaking stakeholders.38
For the approximately 1.2 million daily HM shipments39 in the U.S., CHEMTREC receives an average of
325 calls, about 125 of which are HM incidents from shippers and carriers.
CHEMTREC shared the following information regarding e-communication concerns, gaps, and
vulnerabilities:
38
39
A “many-to-one” relationship between trade names and proper shipping name exists.
Products with the same proper shipping name may have different response requirements.
MSDS date is rarely titled and/or indexed by proper shipping name or technical name.
Trade name information may not be transmitted, retained, mapped, and/or captured in the transfer
www.chemtrec.com/about/Pages/default.aspx.
Estimate was provided via conversation with CHEMTREC staff in 2012 and was based on 2011 HM shipments.
Paperless Hazard Communications Pilot Project
29
of EDI data across networks.
Trade name information may not be readily apparent to responder or caller even if it is shown on
the shipping documents.
Shipping documents are often complex. Many shippers use an ANSI form or their shipping form.
The lack of a required HM form and format causes confusion for some callers. CHEMTREC
suggests the use of a specific HM shipping paper format that has exact fields for entering specific
information about each HM, regardless of the shipper.
Originating shipper information may be “masked” or not readily apparent on the on-scene
shipping documents.
The shipper’s name may have been changed, or may be shown differently, on HM shipments that
undergo multiple transport movements.
CHEMTREC also mentioned that some carriers are often reluctant to let other carriers, and
intermodal carriers, know the identity of their shippers; this scenario is an impediment to
providing timely and accurate information to emergency responders.
4. Pilot Test Planning and Implementation
Activities
PHMSA conducted the following pilot test planning and implementation activities during 2013-2015:
Held meetings with emergency responder and HM inspectors discussing procedures for
emergency response and inspection simulations during the pilot tests;
Published 60- and 30-day notices regarding the execution of paperless HM communication pilot
tests to evaluate the use of e-systems during actual HM shipments to transfer HM information
between HM stakeholders (i.e., shippers, carriers, emergency responders, and law enforcement
inspection personnel) in all transportation modes (air, maritime, rail, and roadway);
Developed data collection forms (pilot test participant selection, inspection, and emergency
response simulation, and impact analysis question sets);
Submitted information collection package (ICP) to OMB in accordance with PRA requirements
and obtained necessary OMB approval;
Evaluated volunteer qualifications and selected pilot test participants;
Developed and conducted pilot test participant regional orientation webinars; and
Coordinated and implemented pilot tests with volunteer participants, including holding weekly
pilot test participant teleconferences.
Each of these activities is further described in the following sections.
Paperless Hazard Communications Pilot Project
30
4.1 Discussion Meetings on Emergency Response and Inspection
Simulation Procedures
On March 13, 2014, PHMSA held two separate roundtable discussions40 with DOT emergency response
representatives and law enforcement inspection entities who had either expressed interest in participating
in, or had previously consulted with PHMSA regarding, the HM-ACCESS Project. The purpose of the
discussions was to obtain feedback regarding their operations for coordinating emergency response and
inspection pilot test simulations in accordance with the specifications identified in the 60-Day, and 30Day Federal Register Notices published on July 19, 2013 (78 FR 43263) and November 25, 2013 (78 FR
70399), respectively. PHMSA provided the following simulation instructions to the participants:
Simulations will be limited to testing e-communication of shipping paper information.
Simulations will be conducted following each agency’s/company’s/organization’s established
emergency response/inspection protocols using their equipment and resources.
One simulation question set should be completed for each emergency response/inspection
simulation conducted during the pilot test, preferably within 24 hours of conducting the actual
simulation.
Emergency responders and inspectors are requested to submit a copy of the e-HM shipping paper
receipt to PHMSA’s HM-ACCESS website inbox.
During the roundtable discussions, PHMSA demonstrated features of the online tool (FluidSurveys™41)
that would be used by pilot test emergency responders and law enforcement inspectors to enter simulation
information electronically. The team also provided examples of the types of data that would be requested
by the simulation question sets.
Participants shared information on their procedures for responding to HM transportation emergencies and
conducting modal HM inspections and provided insightful questions, comments, and suggestions
regarding pilot test simulation implementation.
4.2 60- and 30-Day Notices Regarding the Paperless HM
Communications Pilot Tests
PHMSA published a 60-Day Federal Register Notice entitled “Paperless Hazard Communications Pilot
Program,” on July 19, 2013 (78 FR 43263) in support of MAP-21, Section 33005. This notice described
the HM-ACCESS initiative and planned information collection activities associated with conducting pilot
projects and evaluating potential impacts. The notice also provided an opportunity for stakeholders to
comment on the information collection activities and to volunteer as a potential participant in the pilot
projects. The comment period for the 60-Day Notice closed on September 17, 2013.
The details of the March 2014 roundtable discussion meetings are summarized in two documents on PHMSA’s HM-ACCESS website:
http://phmsa.dot.gov/hazmat/hm-access/stakeholder-information-papers.
41
More information on this tool can be found at www.fluidsurveys.com.
40
Paperless Hazard Communications Pilot Project
31
A copy of the 60-Day Notice is provided in Appendix I: PHMSA’s Paperless Hazard Communications
Pilot Program—60-Day Notice.
PHMSA published a 30-Day Federal Register Notice entitled "Paperless Hazard Communications Pilot
Program," on November 25, 2013 (78 FR 70399) as a follow-up to its Federal Register 60-Day Notice
(posted on July 19, 2013). This notice addressed stakeholder comments received in response to the 60Day Notice and identified the specific questions that would be used for the information collection effort
associated with the pilot projects and for the evaluation of potential impacts (refer to Section 4.3.). The
comment period for the 30-Day Notice closed on December 26, 2013.
A copy of the 30-Day Notice is provided in Appendix J: PHMSA’s Paperless Hazard Communications
Pilot Program, 30-Day Notice.
In addition to being posted in the Federal Register, information regarding both notices was sent via email
to PHMSA’s HM-ACCESS “Serve List,” a compilation of approximately 5,600 individuals and
companies interested in receiving information on the HM-ACCESS Project.
4.3 Pilot Test Participant Selection, Inspection and Emergency
Response Simulation, and Impact Analysis Question Sets
PHMSA developed the following four online question sets to collect project-related information:
Pilot Test Shipper and Carrier Participant Selection Question Set
Pilot Test Inspection Simulation Question Set
Pilot Test Emergency Response Question Set
Impact Analysis Question Set
The Pilot Test Shipper and Carrier Participant Selection Question Set was used to collect information
from potential pilot test shipper and carrier volunteers regarding their ability to meet the criteria identified
in Section 4.5 of this report. A hardcopy of this question set is provided in Appendix K: Pilot Test
Participant Selection Question Set.
The Pilot Test Inspection and Emergency Response Simulation Question Sets were used by pilot test
inspectors and emergency responders to document the pilot test data described in Chapter 5 of this report.
Hard copies of these question sets are provided in Appendix L: Pilot Test Inspection Simulation Question
Set and Appendix M: Pilot Test Emergency Response Simulation Question Set, respectively.
The Impact Analysis Question Set was provided to pilot test volunteers and approximately 3,000
interested parties in the HM community (shippers, carriers, emergency responders, law enforcement
inspectors); Federal, state, and local government agencies; HM/emergency response training
companies/educational associations; HM/emergency response equipment/software developers/vendors;
trade associations; freight forwarders/brokers; and media companies representing all transportation modes
Paperless Hazard Communications Pilot Project
32
(air, maritime, rail, and roadway) who had subscribed to receive HM-ACCESS updates to voluntarily
provide input on the costs, benefits, and challenges associated with implementing e-communication
systems for HM shipping paper information. This data is presented in Chapter 6 of this report. A
hardcopy of this question set is provided in Appendix N: Pilot Test Impact Analysis Question Set.
All four question sets were developed using FluidSurveys™42 online data collection software.
42
https://fluidsurveys.com/
Paperless Hazard Communications Pilot Project
33
4.4 Submitting Pilot Test Information Collection Package to OMB
and Obtaining Approval
PHMSA submitted an ICP on December 19, 2013, to OMB for review and approval, in accordance with
the PRA. PHMSA received OMB approval on the ICP on September 8, 2014, thus enabling PHMSA to
proceed with conducting the inspections and emergency response simulation pilot tests in multiple U.S.
regions (including one rural area as required by MAP-21) and collecting impact analysis information
related to e-HM communications and e-systems.
4.5 Pilot Test Participant Selection
The pilot test participants encompassed representatives from the four major stakeholder categories:
shippers, carriers, emergency responders, and law enforcement inspectors. All other HM interested
parties, such as vendors of e-communication technologies or products, were excluded from pilot test
participation. As indicated within the 60-Day and 30-Day Notices, pilot test participation was voluntary
and volunteering did not guarantee participation.
PHMSA selected shippers and carriers for participation in the pilot tests who met the following
qualifications:
Volunteering entity cannot be an association, but rather needs to an individual entity, as an
association cannot volunteer for its members.
Volunteering entity must qualify as an HM shipper and/or carrier (i.e., the entity must ship and/or
transport HM).
Volunteering entity must have returned to PHMSA within the allotted time a completed Shipper
and Carrier Participant Selection Question Set. Refer to Appendix K: Pilot Test Participant
Selection Question Set for the Shipper and Carrier Participant Selection Question Set.
Volunteering entity must have answered “YES” to questions 4, 6, 7, 10, 11 and 12 of the Shipper
and Carrier Participant Selection Question Set (refer to Appendix K: Pilot Test Participant
Selection Question Set), acknowledging a: (1) willingness to participate; (2) ability to identify a
single coordinating POC; (3) willingness to participate in a pre-pilot orientation meeting; (4)
willingness to participate in inspection and emergency response simulations;43 (5) willingness to
provide feedback and e-HM communication data during pilot tests, as well as information on the
basic function and capabilities of their e-system(s); and (6) understanding the intended use of
collected information and that PHMSA cannot guarantee their company/organization’s identity
will be kept confidential.
Volunteering entity must currently possess an e-system(s) and resources capable of managing and
For purposes of these pilot tests, “simulation” refers to planned exercises designed solely to test the feasibility and effectiveness of using esystems to communicate the needed HM shipping paper information during project-related HM emergency response and inspection scenarios
among pilot test participants. The scope of the simulations was defined by project data collection needs for testing e-communication of shipping
paper information. Emergency response simulations did not involve testing first responder procedures, equipment, or resources not related to the
communication of shipping paper information. (30-Day Notice, Section 3).
43
Paperless Hazard Communications Pilot Project
34
communicating HM shipping paper information at their own expense.
Volunteering entity must ship and/or transport HM within a test region in proximity of
participating emergency response and/or law enforcement organizations.
Volunteering entity must be in good standing with all levels of government and demonstrate
compliance with applicable regulations governing the safe and secure transportation of HM.
Selected emergency responder and law enforcement inspector pilot test participants were those willing to
assist in the collection of information during the inspection and emergency response simulations by
following their established response/inspection protocols using their own equipment and resources and by
completing online Inspection or Emergency Responder Question Sets (refer to Appendix L: Pilot Test
Inspection Simulation Question Set and Appendix M: Pilot Test Emergency Response Simulation
Question Set, respectively, for these question sets). Such entities also were expected to operate within the
regions of the pilot tests where the participating shippers and carriers operate.
Thirty-five different entities across different stakeholder groups were selected as pilot test participants.
The participant numbers by stakeholder group are shown in Table 1.
Table 1. Pilot Test Participants
Stakeholder Group
Shippers
Carriers
Shippers/Carriers
Emergency Responders
Emergency Responders/Law Enforcement Inspectors (NonFederal)
Law Enforcement Inspectors (Non-Federal)
Law Enforcement Inspectors (Federal)
Total:
Number of Entities Vetted to
Participate
7
4
5
6
2
7
4
35
Paperless Hazard Communications Pilot Project
35
4.6 Orientation Webinars for Pilot Test Participants
PHMSA held six pilot test participant orientation webinars in January and February 2015; one for each
pilot test region (Southwestern, Western, Eastern, Southern, and Central),44 and a makeup session for
participants unable to attend their respective regional webinar. All regional pilot test shippers, carriers,
emergency responders, and law enforcement inspectors were invited to attend at least one regional
webinar. During these webinars, the following information was shared with pilot test participants:
Introductions (PHMSA’s HM-ACCESS Team members and other regional pilot test participants);
Goals of the HM-ACCESS Project;
Objectives and expectations of the pilot tests;
Pilot test roles, responsibilities, and schedule;
How to access and complete the online emergency response and inspection simulation question
sets;
Emergency response and inspection simulation expectations;
Format and intended content of final report;
Point-of-contact information for PHMSA’s HM-ACCESS Team members and pilot test
participants; and
Communication procedures during pilot tests.
4.7 Pilot Test Coordination and Implementation
Pilot tests were conducted from February 17, 2015 to May 15, 201545 with selected participants within
five U.S. Regions (Western, Central, Southwestern, Southern, and Eastern) corresponding to PHMSA
field service areas, included, at least, one rural area, as required by MAP-21.The pilot tests collected data
regarding the feasibility, effectiveness, and safety associated with the electronic transfer of HM shipping
paper data between HM stakeholders (shippers, carriers, law enforcement inspectors, and emergency
response personnel) during inspection and emergency response simulations utilizing participants’ existing
equipment and resources.
During the pilot test period, PHMSA invited pilot test participants to take part in weekly teleconferences
to discuss recent emergency response and inspection simulations, including process, efficiencies, and
constraints associated with the e-HM shipping paper data transmissions.
The five U.S. Regions correspond to PHMSA’s Field Service Regions. The Central Region includes Nebraska, North Dakota, South Dakota,
Kansas, Minnesota, Iowa, Missouri, Wisconsin, Illinois, Michigan, Indiana, and Ohio. The Eastern Region includes Maine, New Hampshire,
Vermont, Massachusetts, Rhode Island, Connecticut, New York, New Jersey, Pennsylvania, Maryland, Delaware, Virginia, and West Virginia.
The Southern Region includes Kentucky, Tennessee, South Carolina, North Carolina, Alabama, Mississippi, Florida, and Georgia. The
Southwestern Region includes Texas, New Mexico, Oklahoma, Arkansas, and Louisiana. The Western Region includes California, Nevada, Utah,
Colorado, Arizona, Washington, Oregon, Idaho, Montana, and Wyoming.
45
The pilot tests began on February 17, 2015 and originally were planned to continue for 10 ½ weeks, concluding on April 30, 2015; however,
the test period was extended to May 15, 2015 to allow more time to conduct additional simulations and to satisfy the MAP-21 requirement that at
least one test be conducted in a rural area.
44
Paperless Hazard Communications Pilot Project
36
5. Pilot Test Data
Pilot tests were conducted from February 17, 2015, to May 15, 2015,46 with selected participants within
five U.S. Regions (Western, Central, Southwestern, Southern, and Eastern). The data was collected via
inspectors and emergency responders entering simulation data in the online Pilot Test Inspection
(Appendix L: Pilot Test Inspection Simulation Question Set) and Emergency Response (Appendix M:
Pilot Test Emergency Response Simulation Question Set) Simulation Question Sets. As shown in Table
2, a total of 21 simulations, 16 inspection, and 5 emergency response simulations, were completed during
the pilot test period, including one rural roadway inspection.
Table 2. Total Pilot Test Simulations
Mode
13 (1 in a rural area)
0
3
0
Emergency Response
(ER) Simulations
1
2
1
1
Total Modal
Simulations Completed
14
2
4
1
16
5
21
Inspection Simulations
Roadway
Rail
Maritime
Air
Total Simulations—
All Modes:
Table 3 presents the pilot test simulations by region.
Table 3. Pilot Test Simulations by Region47
Roadway
Maritime
Roadway
Rail
Maritime
Air
Totals
by
Region
Southwestern
2
0
0
0
0
0
2
Central
1
0
0
0
0
0
1
Eastern
8
2 (1 in a
rural area)
0
0
1
1
0
0
10
1
0
0
0
1
2
0
1
1
0
4
13
3
1
2
1
1
21
Inspection Simulations
Region
Southern
Western
Totals:
ER Simulations
4
46
The pilot tests began on February 17, 2015, and originally were planned to continue for ten and a half weeks, concluding on April 30, 2015.
However, the test period was extended to May 15, 2015, to allow more time to conduct additional simulations and to satisfy the MAP-21
requirement that at least one test be conducted in a rural area.
47
The five U.S. Regions correspond to PHMSA’s Field Service Regions. The Central Region includes Nebraska, North Dakota, South Dakota,
Kansas, Minnesota, Iowa, Missouri, Wisconsin, Illinois, Michigan, Indiana, and Ohio. The Eastern Region includes Maine, New Hampshire,
Vermont, Massachusetts, Rhode Island, Connecticut, New York, New Jersey, Pennsylvania, Maryland, Delaware, Virginia, and West Virginia.
The Southern Region includes Kentucky, Tennessee, South Carolina, North Carolina, Alabama, Mississippi, Florida, and Georgia. The
Southwestern Region includes Texas, New Mexico, Oklahoma, Arkansas, and Louisiana. The Western Region includes California, Nevada, Utah,
Colorado, Arizona, Washington, Oregon, Idaho, Montana, and Wyoming.
Paperless Hazard Communications Pilot Project
37
5.1 Pilot Test Volunteer Participants
The 35 entities were vetted to participate in the pilot tests (refer to Table 1), and more than 20 of these
entities participated in the pilot program’s weekly pilot test teleconferences. Due to the availability and
location of vetted shipper and carrier, HM shipments during the pilot test period (February 17, 2015 to
May 15, 2015), only 20 entities had an opportunity to participate in a pilot test simulation. Table 4
identifies the number of entities, by stakeholder group, who actually participated in one or more of the 21
pilot test simulations.
Table 4. Number of Actual Pilot Test Participants by Stakeholder Group
Stakeholder Group
7
4
5
6
2
Number of Entities Who
Actually Participated in
Pilot Test Simulations
4
4
3
3
2
7
4
35
2
2
20
Number of Entities Vetted
to Participate in Pilot Tests
Shippers
Carriers
Shippers/Carriers
Emergency Responders
Emergency Responders/Law Enforcement
Inspectors (Non-Federal)
Law Enforcement Inspectors (Non-Federal)
Law Enforcement Inspectors (Federal)
Totals:
In coordinating simulation logistics, PHMSA sought to find vetted inspectors and emergency responders
available to participate within their operational jurisdictions where vetted shippers and carriers were
shipping/transporting HM during the pilot test period. While many pilot test shippers and carriers adjusted
their HM transport routes to coordinate with inspectors’ and emergency responders’ operational
jurisdictions, some HM transport routes for vetted shippers and carriers did not correspond with vetted
inspector/emergency responder jurisdictional areas, so not all 35 vetted entities were able to participate in
pilot test simulations. Also, as provided in participant description paragraphs in Sections 5.1.1 and 5.1.2,
single vetted entities often participated in multiple pilot test simulations, which increased the amount of
available pilot test data but sometimes provided narrower or skewed results when the data was grouped
and analyzed.
5.1.1
Participating Shippers and Carriers
Descriptions of the four shippers who participated in pilot test simulations are as follows:
Shipper (ID 1) operates primarily in the Western Region of the U.S. and ships HM via air,
maritime, and roadway. Shipper ID 1 participated in one roadway inspection simulation and
offered Class 1 (explosives) in non-bulk packaging (boxes) transported on trucks as HM for the
pilot test inspection simulation.
Paperless Hazard Communications Pilot Project
38
Shipper (ID 2) operates in all five U.S. regions48 and ships HM via air and roadway. Shipper ID 2
participated in one roadway inspection simulation, and offered Class 5 (oxidizing substances and
organic peroxides) in non-bulk packaging (plastic pails) transported on trucks as HM for the pilot
test inspection simulation.
Shipper (ID 3) operates primarily in the Southern Region of the U.S. and ships HM via air,
maritime, rail, and roadway. Shipper ID 3 participated in one maritime inspection simulation and
one emergency response simulation, and offered Class 3 (flammable liquids—100°F or less,
closed cup) in non-bulk packaging (drums and pails), transported via truck on chassis on terminal
as HM for the maritime inspection simulation, and transported on a rail car as HM for the
emergency response simulation.
Shipper (ID 4) operates in all five U.S. regions and ships HM via air, maritime, rail, and roadway.
Shipper ID 4 participated in one emergency response simulation, and offered Class 4 (other
flammable substances) and Class 6 [toxic (poisonous) and infectious substances] transported on a
truck and an airplane as HM for the emergency response simulation.
Descriptions of the four carriers who participated in pilot test simulations are as follows:
Carrier (ID 5) operates in all five U.S. regions and transports HM via roadway. Carrier ID 5
participated in one roadway inspection simulation, and transported Class 3 (flammable liquids—
100°F or less, closed cup) in cargo tanks during the roadway inspection simulation.
Carrier (ID 6) operates in the Western Region of the U.S. and transports HM via maritime and
rail. Carrier ID 6 participated in one maritime inspection simulation and transported Class 3
(flammable liquids—100°F or less, closed cup) in bulk freight containers during the maritime
inspection simulation.
Carrier (ID 7) operates in the Western Region of the U.S. and transports HM via maritime and
rail. Carrier ID 7 participated in two emergency response simulations: during the maritime
emergency response simulation, Carrier ID 7 transported Class 2 (gases) and Class 3 (flammable
liquids—100°F or less, closed cup) on a ship; during the rail emergency response simulation,
Carrier ID 7 transported Class 3 (flammable liquids—100°F or less, closed cup), Class 4 (other
flammable substances), and Class 8 (corrosives) on straddle carriers, rail cars, and ships. This
carrier is a department of an organization that operates as a non-Federal emergency response/law
enforcement inspection organization (refer to emergency response organization (ERO)/law
enforcement inspection organization (LEIO) ID 16).
Carrier (ID 8) operates in the Eastern, Southern, and Southwestern Regions of the U.S. and
transports HM via rail. Carrier ID 8 participated in one emergency response simulation, and
transported Class 3 (flammable liquids—100°F or less, closed cup) on railcars. This carrier has a
department that operates as an emergency responder (refer to ERO ID 14).
The five U.S. Regions correspond to PHMSA’s Field Service Regions. The Central Region includes Nebraska, North Dakota, South Dakota,
Kansas, Minnesota, Iowa, Missouri, Wisconsin, Illinois, Michigan, Indiana, and Ohio. The Eastern Region includes Maine, New Hampshire,
Vermont, Massachusetts, Rhode Island, Connecticut, New York, New Jersey, Pennsylvania, Maryland, Delaware, Virginia, and West Virginia.
The Southern Region includes Kentucky, Tennessee, South Carolina, North Carolina, Alabama, Mississippi, Florida, and Georgia. The
Southwestern Region includes Texas, New Mexico, Oklahoma, Arkansas, and Louisiana. The Western Region includes California, Nevada, Utah,
Colorado, Arizona, Washington, Oregon, Idaho, Montana, and Wyoming.
48
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Descriptions of the three shippers/carriers (S/Cs) who participated in pilot test simulations are as follows:
S/C (ID 9) operates in all U.S. regions and transports HM via roadway. S/C ID 9 participated in
two roadway inspection simulations, and transported Class 2 (gases), Class 3 (flammable
liquids—100°F or less, closed cup), Class 9 (miscellaneous dangerous materials) in bulk
packaging (drums, pails, barrels, and boxes) on trucks during the first roadway inspection
simulation. S/C ID 9 transported Class 2 (gases), Class 3 (flammable liquids—100°F or less,
closed cup), Class 6 [toxic (poisonous) and infectious substances], Class 8 (corrosives), and Class
9 (miscellaneous dangerous materials) in bulk packaging (drums, pails, barrels, boxes, and
cylinders) on trucks during the second roadway inspection simulation.
S/C (ID 10) operates in all U.S. regions and transports HM via air and roadway. S/C ID 10
participated in seven roadway inspection simulations and transported Class 7 (radioactive
materials) in non-bulk packaging (Type A for Class 7 radioactive materials) on trucks and a
passenger car during the roadway inspection simulations.
S/C (ID 11) operates in all five U.S. regions and transports HM via air and roadway. S/C ID 11
participated in one roadway inspection and one emergency response simulation, and transported
Class 2 (gases), Class 7 (radioactive materials), Class 8 (corrosives), and Class 9 (miscellaneous
dangerous goods) in non-bulk packaging (boxes) on trucks during the roadway inspection
simulation and Class 4 (other flammable substances) and Class 6 [toxic (poisonous) and
infectious substances] on a truck and an airplane during the emergency response simulation.
5.1.2
Participating Emergency Response and Law Enforcement Inspection
Organizations
Descriptions of the three EROs who participated in pilot test simulations are as follows:
ERO (ID 12) is a large-sized state organization in the Southern Region that coordinates
emergency response operations at the state level and serves as the initial response element for
emergencies and disasters impacting the state. ERO ID 12 participated in the air emergency
response simulation.
ERO (ID 13) is one of the largest fire departments in the U.S., is located in the Eastern Region,
and responds to more than one million emergencies annually. ERO ID 13 participated in the
roadway emergency response simulation.
ERO (ID 14) is a Class I railroad emergency response department, with operations located in the
Eastern, Southern, and parts of the Central Regions. ERO ID 14 participated in one of the rail
emergency response simulations. This ERO is a division of an HM carrier company (refer to
Carrier ID 8).
Descriptions of the two non-Federal EROs/LEIOs who participated in pilot test simulations are as
follows:
ERO/LEIO (ID 15) is a medium-sized state organization in the Eastern Region chartered to
protect and preserve the state's air, water, and land resources, to enforce environmental laws and
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regulations, to respond to environmental emergencies. ERO/LEIO ID 15 participated in one
roadway simulation.
ERO/LEIO (ID 16) is a private company in the Western Region responsible for public safety and
security at one of the largest U.S. container ports for shipping automotives, bulk, breakbulk, and
heavy lift cargoes. ERO/LEIO ID 16 participated in one maritime inspection simulation and two
emergency response simulations (one rail and one maritime). This ERO/LEIO also has a division
that operates as a carrier at the port (refer to Carrier ID 7).
Descriptions of the two non-Federal LEIOs who participated in pilot test simulations are as follows:
LEIO (ID 17) is a medium-sized state government inspection agency in the Central Region
responsible for safeguarding the security of the state’s regulated motor carrier and rail operations
through inspection and monitoring programs and for enhancing safety at all public highwayrailroad grade crossings. LEIO ID 17 participated in one roadway simulation.
LEIO (ID 18) is a medium-sized state government inspection agency in the Southern Region
responsible for conducting enforcement activities such as inspecting commercial vehicles and
driver logs and patrolling highways for identifying and mitigating truck traffic violations. LEIO
ID 18 participated in two roadway inspection simulations.
Descriptions of the two Federal LEIOs who participated in pilot test simulations are as follows:
LEIO (ID 19) is a division within a Federal agency responsible for inspecting entities who offer
HM for transport and/or transport HM and enforcing current HM transportation laws. LEIO ID 19
participated in nine roadway inspection simulations.
LEIO (ID 20) is a Federal agency whose responsibilities include inspecting containers at ports for
compliance with proper labeling, stowage, and content requirements. LEIO ID 20 participated in
two maritime inspection simulations.
5.2 Inspection Simulations
Sixteen inspection simulations were completed during the pilot test period; thirteen in the Roadway Mode
and three in the Maritime Mode. One of the Roadway inspection simulations was performed in a rural
area. No inspection simulations were performed in the Air and Rail Modes due to the unavailability of
HM shipments in these modes during the pilot test period. General inspection simulation information is
provided in Table 5.
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Table 5. Pilot Test Inspection Simulation Information
Simulation
Date
Simulation
Number
Venue
City
State
Southwestern
02/26/15
11
Home Depot
Parking Lot
Houston
Texas
Central
03/13/15
13
Manufacturing
Facility
Cincinnati
Ohio
Beltsville
Maryland
Maritime
Roadway
Region49
Participants
Involved
ID 19, ID 9
ID 17, ID 1
Eastern
03/18/15
8
Weigh and
Inspection
Station at
Highway Park
and Ride Site
ID 15, ID
10
Southwestern
03/18/15
12
Home Depot
Parking Lot
Katy
Texas
Eastern
03/18/15
1
Shipper/Carrier
Facility
Bel Air
Maryland
ID 19, ID
10
Eastern
03/18/15
2
Hospital
Havre de
Grace
Maryland
ID 19, ID
10
Eastern
03/18/15
3
Shipper/Carrier
Facility
Bel Air
Maryland
ID 19, ID
10
Eastern
03/18/15
4
Hospital
Havre de
Grace
Maryland
ID 19, ID
10
Southern
03/24/15
9
Weigh Station
Greeneville
Tennessee
ID 18, ID
11
Southern
04/24/1550
10
State Road in
Rural Area
Greeneville
Tennessee
Eastern
04/27/15
7
Tank Farm
adjacent to
Port
Philadelphia
Pennsylvania
Eastern
05/08/15
5
Shipper/Carrier
Facility
Bel Air
Maryland
ID 19, ID
10
Eastern
05/08/15
6
Hospital
Havre de
Grace
Maryland
ID 19, ID
10
Region51
Simulation
Date
Simulation
Number
Venue
City
State
Participants
Involved
Western
03/24/15
14
Road inside
Port
Tacoma
Washington
California
Georgia
ID 19, ID 9
ID 18, ID 2
ID 19, ID 5
Western
04/13/15
15
Pier
Los
Angeles
Southern
04/23/15
16
Street inside
Port
Garden City
ID 16, ID 6
ID 20 (no
Shipper or
Carrier was
involved)
ID 20, ID 3
Regions are based on PHMSA’s field services locations.
The inspection simulation conducted on April 24, 2015 in Greeneville, TN, was on a roadway located in a rural area where wireless
connectivity, according to pilot test participants, is not always fully functioning.
51
Regions are based on PHMSA’s field services locations.
49
50
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5.2.1
Description of Roadway Inspection Simulations
LEIO ID 19 conducted 9 of the 13 roadway inspections simulations; LEIO ID 18 conducted 2;
ERO/LEIO ID 15 conducted 1; and LEIO ID 17 conducted 1. Eighty-five percent of these inspection
organizations conduct roadway inspections daily. The other 15% conduct 90 days of compliance
inspections per year or per rating period. Eighty-five percent of roadway inspection simulations were prescheduled; the remaining 15% were unannounced, compared to an average of 27% normally pre-planned
(i.e., conducted as part of a routine inspection program at a checkpoint, waystation, etc.). Also, 73%
normally conducted impromptu (i.e., conducted on the spot based on an observed potential safety risk on
a transportation conveyance) during actual inspection activities. One hundred percent of the 13 roadway
inspectors reported they collected the inspection simulation information electronically from the
shipper/carrier.
S/C ID 10 participated in seven of the roadway inspection simulations, S/C ID 9 participated in two, and
Shipper ID 1, Shipper ID 2, Carrier ID 5, and S/C ID 11 each participated in one. Drivers of the vehicles
carrying the HM were present during all 13 roadway inspection simulations. Drums/pails, barrels, boxes,
cylinders, cargo tanks, and Type A radioactive packages containing Class 1, 2, 3, 5, 6, 7, 8, and 9 HM52
were inspected during the roadway inspection simulations. None of the HM shipments were involved in
intramodal (i.e., transfers between conveyances within a single transportation mode; in these simulations,
roadway) or intermodal (i.e., transfers between transportation modes) transfers. Five of the 13 roadway
inspection simulation shipments were less-than-truckload53 HM shipments.
5.2.1.1
Eastern Region Roadway Inspection Simulations
Six of eight Eastern Region roadway inspection simulations involved the same participants (i.e., LEIO ID
19 and S/C ID 10). These six inspection simulations were conducted on March 18, 2015 (Simulations 1 to
4) and May 8, 2015 (Simulations 5 and 6), and involved Class 7 (radioactive materials) HM packaged in
non-bulk Type A radioactive packages transported on trucks, and all inspection simulations were
performed at fixed sites (shipper/carrier facility or hospital). The inspection information for all six
simulations was collected electronically (driver used cellular/smartphone to contact the S/C; S/C used
cellular/smartphone/tablet to email a pdf copy of shipping paper to inspector’s cellular/smartphone);
matched that recorded on the hardcopy HM shipping papers; and accurately reflected the HM being
transported. Simulation 4 took five minutes or less, Simulations 5 and 6 took 6- to 15 minutes,
Simulations 1 and 3 took 16 to 30 minutes, and Simulation 2 took 31 to 60 minutes to receive the e-HM
information from the time of the request.
52
HM are classified as follows: Class 1—Explosives, Class 2—Gases, Class 3—Flammable Liquids (100°F or less, closed cup), Class 4—Other
Flammable Substances, Class 5—Oxidizing Substances and Organic Peroxides, Class 6—Toxic (Poisonous) and Infectious Substances, Class 7—
Radioactive Materials, Class 8—Corrosives, and Class 9—Miscellaneous Dangerous Materials. Refer to 49 CFR 172.101 for more information.
53
Less than truckload (LTL) is the transportation of a relatively small quantity of freight, usually less than 10,000 pounds, and less than that
required for the application of a truckload rate. LTL carriers use terminal facilities to break and consolidate shipments.
(http://www.transportation-dictionary.org/Less_Than _Truckload, Bureau of Transportation Statistics)
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LEIO ID 19 and S/C ID 10
Roadway Simulations 1-6
Time from Request to Receipt of
E-HM Information
Simulation Number
Count
5 minutes or less
4
1
6 to 15 minutes
5 and 6
2
16 to 30 minutes
1 and 3
2
31 to 60 minutes
2
1
One of the eight Eastern Region roadway inspection simulations involved LEIO ID 19 and Carrier ID 5.
This inspection simulation was conducted on April 27, 2015 (Simulation 7), and involved Class 3
(flammable liquids—100°F or less, closed cup) HM contained and transported in a cargo truck, which
was inspected at a fixed site (tank farm). The inspection information was collected electronically (carrier
used cellular phone to contact its dispatcher, who used a workplace computer to email a pdf copy of the
shipping paper to the inspector’s cellular/smartphone); matched that recorded on the hardcopy HM
shipping papers; accurately reflected the HM being transported; and took 16 to 30 minutes to receive the
e-HM information from the time of request.
LEIO ID 19 and Carrier ID 5
Roadway Simulation 7
Time from Request to Receipt of
E-HM Information
16 to 30 minutes
Simulation Number
Count
7
1
One of the eight Eastern Region roadway inspection simulations involved ERO/LEIO ID 15 and S/C ID
10. This inspection simulation was conducted on March 18, 2015 (Simulation 8), and involved Class 7
(radioactive materials) HM packaged in non-bulk Type A radioactive packages transported in a passenger
car, which was inspected at a weigh-and-inspection station at a highway park and ride site. The inspection
information was collected electronically (carrier used workplace computer to email a pdf copy of the
shipping paper to the inspector’s vehicle laptop computer); matched that recorded on the hardcopy HM
shipping papers; accurately reflected the HM being transported; and took 10 minutes to receive the e-HM
information from the time of request.
ERO/LEIO ID 15 and S/C ID 10
Roadway Simulation 8
Time from Request to Receipt of
E-HM Information
6 to 15 minutes
5.2.1.2
Simulation Number
Count
8
1
Southern Region Roadway Inspection Simulations
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Both of the Southern Region roadway inspection simulations were conducted by LEIO ID 18. The
simulation conducted on March 24, 2015 (Simulation 9) involved S/C ID 11, who transported Class 2
(gases), Class 7 (radioactive materials), Class 8 (corrosives), and Class 9 (miscellaneous dangerous
goods) HM in non-bulk packaging (boxes) on trucks; this conveyance and HM was inspected at a
temporary roadside weigh station. The inspection information was collected electronically (driver
contacted S/C at the office; S/C used workplace computer to email a pdf copy of the shipping paper to the
inspector’s workplace computer; the inspector had a laptop computer with him, and was able to plug it
into the scale at the weigh station to upload the pdf shipping paper to his laptop for viewing during the
inspection); matched that recorded on the hardcopy HM shipping papers; accurately reflected the HM
being transported; and took 5 minutes or less to receive the e-HM information from the time of request.
LEIO ID 18 and S/C ID 11
Roadway Simulation 9
Time from Request to Receipt of
E-HM Information
5 minutes or less
Simulation Number
Count
9
1
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5.2.1.2.1 Southern Region Rural Roadway Inspection Simulation
The simulation conducted on April 24, 2015 (Simulation 10) involved Shipper ID 2, who offered Class 5
(oxidizing substances and organic peroxides) HM in non-bulk packaging (plastic pails) transported on
trucks. This inspection occurred on a state road in a rural area of Tennessee. The inspection information
was collected electronically (shipper attempted to use landline phone, computer aid dispatch (CAD)
terminal, and vehicle laptop to send e-shipping papers to inspector’s cellular phone and vehicle laptop
computer, but was unsuccessful; shipper and inspector moved locations multiple times to attempt to get
electronic connectivity; shipper emailed a pdf copy of the shipping paper to the inspector’s vehicle laptop
computer and CAD terminal); matched that recorded on the hardcopy HM shipping papers; accurately
reflected the HM being transported; and took about 45 minutes to receive the e-HM information from the
time of request.
LEIO ID 18 and Shipper ID 2
Roadway Simulation 10
Time from Request to Receipt of
E-HM Information
31 to 60 minutes
5.2.1.3
Simulation Number
Count
10
1
Southwestern Region Roadway Inspection Simulations
Both Southwestern Region roadway inspection simulations involved the same participants (i.e., LEIO ID
19 and S/C ID 9). These inspection simulations were conducted on February 26, 2015 (Simulation 11)
and March 18, 2015 (Simulation 12). S/C ID 9 transported Class 2 (gases), Class 3 (flammable liquids—
100°F or less, closed cup), and Class 9 (miscellaneous dangerous materials) HM in bulk packaging
(drums, pails, barrels, and boxes) on trucks during Simulation 11, and Class 2 (gases), Class 3 (flammable
liquids—100°F or less, closed cup), Class 6 [toxic (poisonous) and infectious substances], Class 8
(corrosives), and Class 9 (miscellaneous dangerous materials) HM in bulk packaging (drums, pails,
barrels, boxes, and cylinders) on trucks during Simulation 12. Both inspection simulations occurred in a
construction supply store parking lot. The inspection information was collected electronically (for
Simulation 11, the driver used cellular/smartphone/personal digital assistant (PDA) to contact the S/C; the
S/C used a workplace computer to email a pdf copy of the shipping paper to the driver’s laptop computer
and to the inspector’s cellular/smartphone and workplace computer; driver used in-cab printer to print a
copy of the shipping paper; inspector was able to view the shipping paper via both his cellular/smartphone
and the printed copy.
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For Simulation 12, the driver used cellular/smartphone/PDA to contact the S/C; the S/C used a workplace
computer to email a pdf copy of the shipping paper to the driver’s laptop computer and to the inspector’s
cellular/smartphone, workplace computer, and FAX machine. Inspector used the pdf shipping paper on
his cellular/smartphone to conduct the inspection simulation); matched that recorded on the hardcopy HM
shipping papers; accurately reflected the HM being transported; and took five minutes or less to receive
the e-HM information from the time of the request.
LEIO ID 19 and S/C ID 9
Roadway Simulations 11 and 12
Time from Request to Receipt of EHM Information
5 minutes or less
5.2.1.4
Simulation Number
Count
11 and 12
2
Central Region Roadway Inspection Simulation
The Central Region roadway inspection simulation, conducted on March 13, 2015 (Simulation 13),
involved LEIO ID 17 and Shipper ID 1, who offered Class 1 (explosives) HM in non-bulk packaging
(boxes) transported on trucks; this inspection simulation was performed at a manufacturing facility. The
inspection information was collected electronically (shipper was contacted via cellular phone, contact was
made outside of shipper’s normal hours of business, and shipper was not set up for e-shipping paper
transfer outside of normal business hours during pilot test; shipper faxed a pdf copy of the shipping paper
to the inspector’s vehicle laptop computer and office FAX machine); matched that recorded on the
hardcopy HM shipping papers; accurately reflected the HM being transported; and took 4 hours and 3
minutes to receive the e-HM information from the time of the request.54
LEIO ID 17 and Shipper ID 1
Roadway Simulation 13
Time from Request to Receipt of
E-HM Information
More than one hour
5.2.2
Simulation Number
Count
13
1
Description of Maritime Inspection Simulations
Two maritime inspection simulations were conducted by LEIO ID 20, and the third was conducted by
ERO/LEIO ID 16. Thirty-three percent of these organizations conduct daily inspections, 33% conduct
weekly inspections, and 33% conduct inspections as needed. Pilot test shippers/carriers participated in
two of these inspections; terminal personnel participated in the third inspection simulation. All three
(100%) maritime inspection simulations were pre-scheduled, compared to an average of 60% normally
pre-planned and 40% normally conducted impromptu during actual inspection activities.
The delay in receipt of the e-shipping paper resulted because initial contact for the e-shipping paper was made outside of shipper’s normal
hours of business, and shipper was not set up for e-shipping paper transfer outside of normal business hours during the pilot test period.
54
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Carrier ID 6 and Shipper ID 3 each participated in one of the maritime inspection simulations; the third
maritime inspection simulation did not involve any vetted shippers or carriers; rather, this inspection
simulation involved personnel at the terminal where the HM container was located. No vehicle drivers or
ship captains responsible for the HM containers were present during the simulations. Drums/pails, boxes,
and freight containers containing Class 1 and 3 HM were inspected during the maritime inspection
simulations. One HM shipment was involved in an intramodal transfer; HM shipping paper information
was communicated via the Internet during the transfer. The inspectors did not know if any intermodal
transfers had occurred prior to the inspection simulations.
5.2.2.1
Western Region Maritime Inspection Simulations
Two Western Region, maritime-inspection simulations were conducted. The first, conducted on March
24, 2015 (Simulation 14), involved ERO/LEIO ID 16 and Carrier ID 6, who transported Class 3
(flammable liquids—100°F or less, closed cup) HM in bulk freight containers; this inspection simulation
was performed on a road in the port. The inspection information was collected electronically (carrier used
cellular/smart/landline phone and workplace computer to email a pdf copy of the shipping paper in EDI
language to the inspector’s workplace computer and cellular/smartphone); matched that recorded on the
hardcopy HM shipping papers; accurately reflected the HM being transported; and took five minutes or
less to receive the e-HM information from the time of request.
ERO/LEIO ID 16 and Carrier ID 6
Maritime Simulation 14
Time from Request to Receipt of
E-HM Information
5 minutes or less
Simulation Number
Count
14
1
The second Western Region maritime inspection simulation was conducted on April 13, 2015 (Simulation
15) by LEIO ID 20; no shipper or carrier was involved in this simulation. LEIO ID 20 inspected Class 1
(explosives) HM in non-bulk packaging (boxes) at a pier at one of the port’s terminals. The inspection
information was collected electronically (inspector called the terminal prior to the inspection using a
landline phone to request the HM shipping paper; terminal personnel emailed a pdf copy of the shipping
paper to the inspector’s workplace computer; inspector then printed a copy of the shipping paper and
brought it to the inspection location); matched that recorded on the hardcopy HM shipping papers;
accurately reflected the HM being transported; no information was provided on how long it took for the
LEIO to receive the e-HM information from the time of request.55
5.2.2.2
Southern Region Maritime Inspection Simulation
The Southern Region maritime inspection simulation, conducted on April 23, 2015 (Simulation 16),
involved LEIO ID 20 and Shipper ID 3, who offered Class 3 (flammable liquids—100°F or less, closed
cup) HM in non-bulk packaging (drums and pails), transported via truck on chassis. This inspection was
55
The inspector who conducted Simulation 15 transferred from the LEIO and cannot be reached for clarifying how long it took for receipt of the
e-HM information from the time of request. In addition, no vetted shipper or carrier was involved in this simulation, so PHMSA could not contact
a shipper or carrier to obtain this information.
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performed on a street in the port. The inspection information was collected electronically (shipper used
workplace computer to email a pdf copy of the shipping paper to the inspector’s workplace computer;
inspector then printed a copy of the shipping paper and brought it to the inspection location); matched that
recorded on the hardcopy HM shipping papers; accurately reflected the HM being transported; and took
26 minutes to receive the e-HM information from the time of request.
LEIO ID 20 and Shipper ID 3
Maritime Simulation 16
Time from Request to Receipt of EHM Information
Simulation Number
Count
16
1
16 to 30 minutes
5.2.3
Inspection Simulation Data
The 13 roadway and three maritime inspectors who received the HM shipping paper information
electronically from the shippers/carriers during the simulations reported the following receipt times listed
in Table 6.
Table 6. Inspection Simulations—E-data Receipt Times
Roadway Inspection
Simulations
Maritime Inspection
Simulation56
Time from Request to Receipt of
E-HM Information
Simulation
Number
Count
Percent of
Total by
Mode
Simulation
Number
Count
Percent of
Total by
Mode
5 minutes or less
4, 9, 11, 12
4
31%
14
1
50%57
6 to 15 minutes
5, 6, 8
3
23%
--
0
0%
16 to 30 minutes
1, 3, 7
3
23%
16
1
50%58
31 to 60 minutes
2, 10
2
15%
--
0
0%
13
1
8%
--
0
0%
More than one hour59
From the time of the request, in almost all cases it took less than 60 minutes to receive the e-HM
information; the majority of the time it took less than 30 minutes, and approximately half the time it took
less than 15 minutes. The one roadway simulation where it took more than one hour to receive the e-HM
information was due to the shipper not being prepared to provide e-HM information during non-working
hours (simulation was conducted in a different time zone than where the shipper’s business was located).
56
Time from request to receipt of e-HM information was not provided for the April 13, 2015 Maritime Inspection Simulation (Simulation 15).
The inspector that conducted the simulation switched jobs and no current contact information is available. In addition, no vetted shipper or carrier
was involved in this simulation, so PHMSA could not contact a shipper or carrier to obtain this information.
57
This percent represents known receipt times, based on inspector responses to the inspection simulation question sets.
58
Ibid.
59
The roadway inspector reported an e-HM information receipt time of 4 hours, 3 minutes. The inspector indicated that the delay was a result of
the shipper not currently being set up for electronic information transfer outside of normal business hours. In addition, several staff were involved
in faxing the shipping paper, which contributed to the delay in the inspector’s receipt of the HM information. The maritime inspector reported an
e-HM information receipt time of approximately one business day; no reason for the delay in receiving the information was provided.
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No information was provided on how long it took to receive the e-HM information in the third maritime
simulation (Simulation 15). Table 7 summarizes the documentation reviewed by the inspectors.
Table 7. Documentation Reviewed During Inspection Simulations
Roadway Simulations
Maritime Simulations
Count60
Percentage
Count
Percentage
HM shipping papers
11
85%
3
100%
Bill of lading
2
15%
1
33%
Other61
3
23%
2
67%
Emergency response information
4
31%
2
67%
Documentation
Total Responses:
Roadway: 13
Maritime: 3
The shipping paper elements requested by the inspectors during the inspection simulations are identified
in Appendix B: HM Shipping Paper Elements.
The inspectors reported that the shippers/carriers used the devices and e-data exchange languages
identified in Table 8 to send the HM shipping paper information to them in support of the inspection
simulations.
Table 8. Devices and Electronic Data Exchange Languages Used by Shippers/Carriers to Send HM Shipping Paper
Information to Inspectors
Roadway Simulations
Maritime Simulations
Device
Count
Percentage
Count
Percentage
PDAs
2
15%
0
0%
Vehicle laptops
1
8%
0
0%
Workplace computers
3
23%
2
67%
CAD terminals
1
8%
0
0%
Landline telephones
1
8%
1
33%
Cellular telephones
9
69%
1
33%
Smartphones
6
46%
1
33%
FAX machines
1
8%
0
0%
The sum of the “Counts” value column is often higher that the “Total Responses” number in Table 7, Table 8, and
Table 9 because each inspector may look at more than one document and use multiple devices, communication methods, etc.
61
The “Other” documentation reviewed by the roadway inspectors included universal HM manifests, commercial driver’s licenses, log books,
and vehicle registrations. The “Other” documentation reviewed by the maritime inspectors included internal port vessel terminal reports and
dangerous goods declarations.
60
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Roadway Simulations
Maritime Simulations
Tablets
6
46%
0
0%
Unknown
0
0%
1
33%
Other62
1
8%
0
0%
Total Responses:
Data Exchange Language
Roadway: 13
Maritime: 3
Count
Percentage
Count
Percentage
Unknown
12
92%
3
100%
Other63
1
8%
0
0%
Total Responses:
Roadway: 13
Maritime: 3
The inspectors used the devices, e-data exchange languages, communication mechanisms, and e-data
formats identified in
Table 9 to receive the HM shipping paper information during the inspection simulations.
Table 9. Devices, Electronic Data Exchange Languages, Communication Mechanisms, and Electronic Data Formats Used
by Inspectors to Receive the HM Shipping Paper Information
Roadway Simulations
Maritime Simulations
Device
Count
Percentage
Count
Percentage
PDAs
1
8%
0
0%
Vehicle laptops
3
23%
0
0%
Workplace computers
1
8%
2
67%
CAD terminals
1
8%
0
0%
Landline telephones
1
8%
1
33%
Cellular telephones
6
46%
1
33%
Smartphones
8
62%
1
33%
FAX machines
1
8%
0
0%
Two-way radios
0
0%
1
33%
None, no technology available
0
0%
1
33%
The roadway inspector indicated that the shipper/carrier used a printer as the “Other” device to send the HM information.
The roadway inspector indicated that the shipper/carrier used cloud/sky technology as the “Other” data exchange language to send the HM
information.
62
63
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51
Roadway Simulations
Other64
1
Total Responses:
Data Exchange Language
8%
Maritime Simulations
2
67%
Roadway: 13
Maritime: 3
Count
Percentage
Count
Percentage
EDI
0
0%
1
33%
None, no electronic data was exchanged
0
0%
0
0%
Unknown
12
92%
2
67%
Other65
1
8%
0
0%
Total Responses:
Communication Mechanism
Roadway: 13
Maritime: 3
Count
Percentage
Count
Percentage
Email
12
92%
3
100%
Direct device-to-device transmission
0
0%
1
33%
FAX document
2
16%
0
0%
Audio transmission (via phone, radio, etc.)
2
15%
2
67%
Other66
0
0%
1
33%
Total Responses:
Electronic Data Format
Roadway: 13
Maritime: 3
Count
Percentage
Count
Percentage
Portable Document Format (pdf)
10
77%
3
100%
Joint Photographic Experts Group (jpeg)
1
8%
0
0%
None, no electronic data was exchanged
1
8%
0
0%
Unknown
1
8%
0
0%
Total Responses:
Roadway: 13
Maritime: 3
5.3 Emergency Response Simulations
“Other” device use by a roadway simulation inspector was a laser printer. “Other” device use by maritime simulation inspectors was a printed
hardcopy of an emailed pdf shipping paper.
65
“Other” data exchange language used by a roadway inspector was a mobile device using cloud/sky technology.
66
“Other” communication mechanism used by a maritime inspector was a hardcopy paper document provided prior to the inspection simulation.
64
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Five emergency response (ER) simulations were completed during the pilot test period; one each in the
Air, Maritime, and Roadway Modes, and two in the Rail Mode. General ER simulation information is
provided in Table 10.
Table 10. Pilot Test Emergency Response Simulation Locations
Mode
Air
Region
Simulation
Date
Simulation
Number
Southern
03/11/15
17
Rail
Western
03/31/15
18
Roadway
Eastern
04/21/15
20
Maritime
Western
04/27/15
19
Rail
Eastern
05/06/15
21
5.3.1
Venue
City
State
Road on
airport
property
Rail track
Fort
Lauderdale
Florida
in
Intermodal
yard at a
port
Shipper
terminal
Pier at a
port
Class 1 rail
yard
Participants
Involved
ID 12, ID 4,
ID 11
ID 16, ID 7
Tacoma
Washington
Brooklyn
New York
Tacoma
Washington
Selkirk
New York
ID 13, ID 5
ID 16, ID 7
ID 14, ID 8,
ID 3
Description of Emergency Response Simulations
ERO ID 12 conducted the March 11, 2015 Air Mode ER simulation, ERO/LEIO ID 16 conducted the
March 31, 2015 Rail Mode and the April 27, 2015 Maritime Mode ER simulations, ERO ID 13 conducted
the April 21, 2015 Roadway Mode ER simulation, and ERO ID 14 conducted the May 6, 2015 Rail Mode
ER simulation. All five ER organizations have public safety answering points (PSAPs) with jurisdiction
for the locations where the ER simulations were conducted. 40% of these ER organizations respond to
HM incidents daily, and respond to over 100 HM incidents annually (ERO ID 12 and ERO ID 13); 20%
respond to HM incidents weekly, and respond to 51 to 100 HM incident annually (ERO ID 14); and 40%
respond to HM incidents approximately four times each year, and respond to zero to five HM Rail Mode
incidents and 11 to 50 Maritime Mode HM incidents annually (ERO/LEIO ID 16).
Shipper ID 4 and S/C ID 11 participated in the March 11, 2015 Air Mode ER simulation, Carrier ID 7
participated in the March 31, 2015 Rail Mode and April 27, 2015 Maritime Mode ER simulations, Carrier
ID 5 participated in the April 21, 2015 Roadway Mode ER simulation, and Shipper ID 3 and Carrier ID 8
participated in the May 6, 2015 Rail Mode ER simulation.
All five ER simulations were pre-scheduled and included the following mock responses to ER scenarios
rather than immediate responses to actual HM transportation emergencies:
An HM emergency on an airplane
An HM emergency aboard a marine vessel
An HM emergency on a roadway
An HM emergency on a railcar (two Rail Mode ER simulations)
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The emergency responders indicated that the ER simulation information was collected electronically for
at least part of all five ER simulations (100%).
Drivers/vessel agents were present during the air, maritime, and roadway ER simulations (60%). Planes,
ships, railcars, trucks, and straddle carrier HM transportation conveyances carrying Class 2, 3, 4, 6, and 8
HM were involved in the ER simulations. The Air Mode ER simulation involved a less-than-truckload
HM shipment.
5.3.1.1
Southern Region ER Simulation
The Southern Region Air Mode ER simulation, conducted on March 11, 2015 (Simulation 17), involved
ERO ID 12, Shipper ID 4, and S/C ID 11, who offered Class 4 (other flammable substances) and Class 6
[toxic (poisonous) and infectious substances] HM transported on trucks and planes; this ER simulation
was conducted at a road inside an airport. The HM shipping paper information was collected
electronically (the shipper used a cellular/ smartphone to call the ERO’s and the S/C’s
cellular/smartphone and notify them of the simulated emergency; the ERO requested HM shipping paper
information; the shipper and the S/C emailed a pdf copy of the shipping paper in XML to the ERO’s
cellular/smartphone, PDA, and vehicle laptop computer; the local county HM team were first to arrive at
the scene); matched that recorded on the hardcopy HM shipping papers; accurately reflected the HM
being transported; and was received instantaneously by the responder upon request.
ERO ID 12, Shipper ID 4, and S/C ID 11
ER Simulation 17
Time from Request to Receipt of
E-HM Information
Simulation Number
Count
17
1
Instantaneously
5.3.1.2
Western Region ER Simulations
The Western Region Rail Mode ER simulation, conducted on March 31, 2015 (Simulation 18), involved
ERO/LEIO ID 16 and Carrier ID 7, who offered Class 3 (flammable liquids—100°F or less, closed cup),
Class 4 (other flammable substances), and Class 8 (corrosives) HM transported on straddle carriers,
railcars, and ships; this ER simulation was conducted at a rail track in an Intermodal yard at a port. The
HM shipping paper information was collected electronically (Simulation 18 involved PSAP dispatch,
police, port patrol/security, and internal port dispatch personnel; port patrol personnel arrived on scene
first, and contacted the police via landline/cellular/smartphone; police officer then contacted the
intermodal yard rail coordinator via two-way radio/smartphone to request the HM shipping paper;
intermodal yard rail coordinator emailed police officer the HM shipping paper in jpeg format from his
workplace computer/PDA to the police officer, who received the e-shipping paper via PDA/workplace
computer; port patrol/security received the e-shipping paper via PDA, workplace computer, and
cellular/smartphone); matched that recorded on the hardcopy HM shipping papers; accurately reflected
the HM being transported; and took 6 to 15 minutes for the ERO/LEIO to receive the e-HM information
from the time of request.
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ERO/LEIO ID 16 and Carrier ID 7
ER Simulation 18
Time from Request to Receipt of
E-HM Information
Simulation Number
Count
18
1
6 to 15 minutes
The Western Region Maritime Mode ER simulation, conducted on April 27, 2015 (Simulation 19), also
involved ERO/LEIO ID 16 and Carrier ID 7, who offered Class 2 (gases) and Class 3 (flammable
liquids—100°F or less, closed cup) HM transported on ships; this ER simulation was conducted at a pier
at a port. The HM shipping paper information was collected electronically (Simulation 19 involved PSAP
dispatch, fire, and Port of Tacoma patrol personnel; the shipper contacted port patrol personnel, who
arrived on scene first; port PSAP dispatch used workplace computer, cellular/smartphone, and video to
email shipping paper in pdf format to port patrol personnel; PDAs and two-way radios were also used for
audio communications);matched that recorded on the hardcopy HM shipping papers; accurately reflected
the HM being transported; and took 5 minutes or less for the ERO/LEIO to receive the e-HM information
from the time of request.
ERO/LEIO ID 16 and Carrier ID 7
ER Simulation 19
Time from Request to Receipt of
E-HM Information
Simulation Number
Count
19
1
5 minutes or less
5.3.1.3
Eastern Region ER Simulations
The Eastern Region Roadway Mode ER simulation, conducted on April 21, 2015 (Simulation 20),
involved ERO ID 13 and Carrier ID 5, who offered Class 3 (flammable liquids—100°F or less, closed
cup) HM transported on trucks; this ER simulation was conducted at a shipper terminal. The HM shipping
paper information was collected electronically (fire personnel arrived on-scene first; driver used cellular
phone to call terminal manager and request the HM shipping paper; terminal manager used cellular phone
to call carrier and request permission to send HM shipping paper to driver; carrier granted permission, so
terminal manager emailed a pdf copy of the shipping paper to the driver’s cellular phone; driver then
emailed the pdf shipping paper to the fire emergency responder’s tablet); matched that recorded on the
hardcopy HM shipping papers; accurately reflected the HM being transported; and took 23 minutes for
the ERO to receive the e-HM information from the time of request.
ERO ID 13 and Carrier ID 5
ER Simulation 20
Time from Request to Receipt of
E-HM Information
16 to 30 minutes
Simulation Number
Count
20
1
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The Eastern Region Rail Mode ER simulation, conducted on May 6, 2015 (Simulation 21), involved ERO
ID 14, Shipper ID 3, and Carrier ID 8, who transported Class 3 (flammable liquids—100°F or less, closed
cup) HM on railcars; this ER simulation was conducted at a Class 1 rail yard. The HM shipping paper
information was collected electronically (carrier field personnel arrived on-scene first, acted in a PSAP
capacity, and used PDA/smartphone to call ERO to report the incident; ERO used smartphone to call
CHEMTREC; CHEMTREC used workplace computer to email a pdf copy of the shipping paper to the
ERO’s smartphone and workplace computer; ERO used smartphone/workplace computer to email
shipping paper to the carrier field personnel’s smartphone and I-Pad; CHEMTREC then used landline
phone to call shipper, and requested shipper call ERO; shipper used smartphone to call ERO’s
smartphone to confirm shipping paper emailed by CHEMTREC was correct); matched that recorded on
the hardcopy HM shipping papers; accurately reflected the HM being transported; and took 5 minutes or
less for the ERO to receive the e-HM information from the time of request.
ERO ID 14, Shipper ID 3, and Carrier ID
8
ER Simulation 21
Time from Request to Receipt of
E-HM Information
Simulation Number
Count
21
1
5 minutes or less
5.3.2
Emergency Response Simulation Data
The emergency response personnel who received the HM shipping paper information electronically
during the simulations reported the receipt times listed in Table 11.
Table 11. ER Simulations—E-data Receipt Times
Totals
Time from Request to Receipt of
E-HM Information
Simulation
Number
Count
Percentage
17
1
20%
5 minutes or less
19, 21
2
40%
6 to 15 minutes
18
1
20%
16 to 30 minutes
20
1
20%
Instantaneous
The shipping paper elements requested by and provided to emergency response personnel during the ER
simulations are identified in Appendix B: HM Shipping Paper Elements.
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5.3.2.1
Initial E-HM Information Requested by PSAP Dispatchers (or Equivalent
Personnel)
No attempt was made to electronically transmit HM information to the PSAP dispatcher during the April
21, 2015 Roadway ER simulation (Simulation 20). The devices and e-data exchange languages identified
in
Table 12 were used to send the HM shipping paper information to the PSAP dispatchers (or equivalent
personnel) during the four ER simulations that had e-communication with the PSAP dispatchers (or
equivalent personnel).
Table 12. Devices and Electronic Data Exchange Languages Used to Send E-Information to the Dispatchers
Air
Simulation
17
Rail
Simulation
18
Maritime
Simulation
19
Rail
Simulation
21
Count
Count
Count
Count
Count
%
Workplace computers
0
1
1
1
3
75%
Cellular telephones
0
1
1
0
2
50%
Smartphones
0
1
1
0
2
50%
Landline telephones
0
1
0
0
1
25%
Videos
0
0
1
0
1
25%
Two-way radios
0
1
0
0
1
25%
Unknown
1
0
0
0
1
25%
Other
0
0
0
0
0
0%
Count
Count
Count
Count
Count
%
XML
1
0
0
0
1
25%
Unknown
0
1
1
1
3
75%
Other
0
0
0
0
0
0%
Device
Data Exchange
Language
Totals
Table 13 lists the devices, e-data exchange languages, communication mechanisms, and data formats used
by the PSAP dispatchers (or equivalent personnel) to receive the HM shipping paper information during
the ER simulations.
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57
Table 13. Devices, Electronic Data Exchange languages, Communication Mechanisms, and Electronic Data Formats Used
by PSAP Dispatchers to Receive E-Information
Air
Simulation
17
Rail
Simulation
18
Maritime
Simulation
19
Rail
Simulation
21
Count
Count
Count
Count
Count
%
Cellular telephones
1
1
1
0
3
75%
Workplace computers
0
1
1
1
3
75%
PDAs
1
0
0
0
1
25%
Vehicle laptops
1
0
0
0
1
25%
Landline telephones
0
1
0
0
1
25%
Smartphones
0
1
0
1
2
50%
Videos
0
0
1
0
1
25%
Two-way radios
0
1
0
0
1
25%
Other
0
0
0
0
0
0%
Count
Count
Count
Count
Count
%
XML
1
0
0
0
1
25%
Unknown
0
1
1
1
3
75%
Other
0
0
0
0
0
0%
Count
Count
Count
Count
Count
%
Email
1
1
1
1
4
100%
Direct device-todevice transmission
0
0
1
0
1
25%
Internet reference/link
0
0
1
0
1
25%
Audio transmission
(e.g., via phone, radio,
etc.(
0
0
1
0
1
25%
Other
0
167
168
0
2
50%
Count
Count
Count
Count
Count
%
1
0
1
1
3
75%
Device
Data Exchange
Language
Communication
Mechanism
Electronic Data
Format
PDF
Totals
“Other” communication mechanism used by a maritime inspector was a hardcopy paper document provided prior to the inspection simulation.
mentation.
68
“Other” communication mechanism used in Maritime ER Simulation was face-to-face communication and hardcopy backup of e-HM
information.
67
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58
JPEG
0
1
0
0
1
25%
Other
0
0
0
0
0
0%
PSAP dispatchers (or equivalent personnel) conducted follow-up activities for four of the ER simulations.
These activities are described in Table 14.
Table 14. Follow-Up Dispatch Actions
Simulation Number and Date
Mode
17
March 11, 2015
Air
18
March 31, 2015
Rail
19
April 27, 2015
Maritime
21
May 6, 2015
Rail
5.3.2.2
Dispatch Follow-up Activity
Obtained entire aircraft cargo manifest.
Responding patrol officer contacted North
Intermodal Tower to obtain electronic copy of
"Dangerous Goods for Multimodal Transport" HM
info. Also received hardcopy of same document.
Port of Tacoma Patrol Communications had already
received an electronic copy of the amount of
vehicles/trucks being offloaded from the vessel. The
electronic copy was also made available to
Responding port officer.
Contacted shipper to obtain bill of lading, SDS, and
other HM documentation
Communications with Emergency Responders Prior to Their Arrival On-Scene
No attempt was made by any entity to provide emergency responders with e-HM information prior to
their arrival on-scene during the April 21, 2015 Roadway ER simulation (Simulation 20). The other four
ER simulations did include some attempts at providing e-HM information to emergency responders prior
to their arrival on-scene during the ER simulation. These communication attempts are summarized in
Table 15.
Table 15. E-HM Communications with Emergency Responders Prior to On-Scene Arrival
Air
Simulation
17
Rail
Simulation
18
Maritime
Simulation
19
Rail
Simulation
21
Answer
Answer
Answer
Answer
YES
Count
%
Driver/pilot/captain/conductor
Yes
Yes
Yes
No
3
75%
PSAP dispatcher (or equivalent)
Yes
Yes
Yes
Yes
4
100%
Shipper
No
Yes
Yes
Yes
3
75%
Carrier
No
Yes
Yes
Yes
3
75%
Other entity
No
Yes
Yes
No
2
50%
2
5
5
3
Did Entity Attempt to Provide E-HM
Information to Emergency
Responder?
“Yes” Totals by Simulation:
Totals
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5.3.2.2.1 Air Mode ER Simulation Data
The March 11, 2015 Air ER simulation (Simulation 17) e-HM communication devices, languages,
mechanisms, and formats used to communicate with emergency responders prior to their arrival on-scene
is provided in Table 16.
Table 16. Air (Simulation 17)—Devices, Electronic Data Exchange Languages, Communication Mechanisms, and
Electronic Data Formats Used to Communicate with Emergency Responders Prior to On-Scene Arrival
Used by Driver,
etc.
Device
Received by
Emergency
Responder
PDAs
Used by PSAP
Received by
Emergency
Responder
X
Vehicle laptops
Smartphones
Unknown
X
Data Exchange Language
XML
Communication Mechanism
Used by Driver,
etc.
Received by
Emergency
Responder
Used by PSAP
Received by
Emergency
Responder
X
X
Used by Driver,
etc.
Received by
Emergency
Responder
Used by PSAP
Received by
Emergency
Responder
X
Used by PSAP
Received by
Emergency
Responder
X
Email
None
Electronic Data Format
X
Used by Driver,
etc.
Received by
Emergency
Responder
PDF
None, no electronic data was exchanged
X
5.3.2.2.2 Rail Mode ER Simulations Data
The March 31, 2015 and May 6, 2015 Rail ER simulations (Simulations 18 and 21) e-HM communication
devices, languages, mechanisms, and formats used to communicate with emergency responders prior to
their arrival on-scene is provided in Table 17.
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60
Table 17. Rail (Simulations 18 and 21)—Devices, Electronic Data Exchange Languages, Communication Mechanisms,
and Electronic Data Formats Used to Communicate with Emergency Responders Prior to On-Scene Arrival
Device
Used
by
Driver,
etc.
PDAs
X
Workplace
computers
X
Received
by ER
Used
by
PSAP
Received
by ER
Used
by
Shippe
r
Received
by ER
Received
by ER
Used
by
Other
Received
by ER
X
X
X
X
X
X
X
X
Smartphones
X
X
X
FAX machines
X
X
X
Two-way radios
X
X
Landline
telephones
Cellular phones
X
X
X
Used
by
Carrier
Used
by
PSAP
Received
by ER
X
X
X
Unknown
X
Used
by
Driver,
etc.
Received
by ER
Used
by
PSAP
Received
by ER
Used
by
Shippe
r
Received
by ER
Used
by
Carrier
Received
by ER
Used
by
Other
Received
by ER
Used
by
PSAP
Received
by ER
X
X
X
X
X
Received
by ER
Used
by
PSAP
Received
by ER
Used
by
Shippe
r
Received
by ER
Used
by
Carrier
Received
by ER
Used
by
Other
Received
by ER
Used
by
PSAP
Received
by ER
X
X
X
X
X
Internet
reference/link
X
X
X
FAX document
X
X
X
X
Used
by
Other
Received
by ER
Used
by
PSAP
Received
by ER
X
Other69
Data Exchange
Language
Unknown
None
Communication
Mechanism
Used
by
Driver,
etc.
Audio
transmission
X
PDF
JPEG
Used
by
Driver,
etc.
X
X
X
X
X
Used
by
PSAP
Received
by ER
Used
by
Shippe
r
Received
by ER
Used
by
Carrier
Received
by ER
X
Other70
Electronic Data
Format
X
Email
None
Received
by ER
X
“Other” device used by the driver and the carrier was a copy machine to make a hardcopy of the HM documentation. “Other” device used by
the responder to receive the e-HM information from all entities was internal port closed-circuit televisions (CCTVs).
70
“Other” communication mechanism between PSAP and responders was the CCTVs. Face-to-face verbal communication was used between the
shipper’s port agent and the responders, and between the carrier’s port agent and the responders.
69
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61
Device
Used
by
Driver,
etc.
Received
by ER
Used
by
PSAP
Received
by ER
X
X
None, no
electronic data
was exchanged
Used
by
Shippe
r
Received
by ER
Used
by
Carrier
Received
by ER
X
Unknown
Used
by
Other
Received
by ER
Used
by
PSAP
Received
by ER
5.3.2.2.3 Maritime Mode ER Simulation Data
The April 27, 2015 Maritime ER simulation (Simulation 19) e-HM communication devices, languages,
mechanisms, and formats used to communicate with emergency responders prior to their arrival on-scene
is provided in
Table 18.
Table 18. Maritime (Simulation 19)—Devices, Electronic Data Exchange Languages, Communication Mechanisms, and
Electronic Data Formats Used to Communicate with Emergency Responders Prior to On-Scene Arrival
Device
Used by
Driver,
etc.
Received
by ER
Used by
PSAP
Received
by ER
Used by
Shipper
Received
by ER
Used by
Carrier
Received
by ER
Vehicle laptops
X
X
X
X
X
X
X
X
X
X
Landline telephones
Cellular phones
Used by
Other
PDAs
Workplace computers
Received
by ER
X
Smartphones
Videos
X
X
Live web cameras
Two-way radios
X
Other71
X
Used by
Driver,
etc.
Received
by ER
Used by
PSAP
Received
by ER
Used by
Shipper
Received
by ER
Used by
Carrier
Received
by ER
Used by
Other
Received
by ER
X
X
X
X
X
Used by
Driver,
etc.
Received
by ER
Used by
PSAP
Received
by ER
Used by
Shipper
Received
by ER
Used by
Carrier
Received
by ER
Used by
Other
Received
by ER
Email
X
X
X
X
X
Direct device-to-device
transmission
X
X
Data Exchange
Language
Unknown
Communication
Mechanism
“Other” devices used between PSAP dispatchers and responders, and between other entity and responders to communicate HM information
included face-to-face verbal communication with port operations personnel.
71
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62
Used by
Driver,
etc.
Used by
PSAP
Received
by ER
Internet reference/link
X
Audio transmission
X
Device
Received
by ER
Used by
Shipper
Received
by ER
X
Other72
Electronic Data
Format
Used by
Carrier
Received
by ER
Used by
Other
Received
by ER
X
X
X
Used by
Driver,
etc.
Received
by ER
Used by
PSAP
Received
by ER
Used by
Shipper
Received
by ER
Used by
Carrier
Received
by ER
Used by
Other
Received
by ER
X
X
X
X
X
Unknown
5.3.2.3
On-Scene Communications with Emergency Responders
No attempt was made by any entity to provide emergency responders with e-HM information while they
were on-scene during the March 11, 2015 Air and March 31, 2015 Rail simulations (Simulations 17 and
18). The other three ER simulations did include some attempts at providing e-HM information to
emergency responders while on-scene during the ER simulation. These communication attempts are
summarized in Table 19.
Table 19. E-HM Communications with Emergency Responders While On-Scene
Maritime
Simulation 19
Roadway
Simulation 20
Rail
Simulation
21
Answer
Answer
Answer
YES73
Count
%
Driver/pilot/captain/conductor
Yes
Yes, but
unsuccessful74
Yes
2
50%
PSAP dispatcher (or
equivalent)
Yes
No
Yes
2
67%
Shipper
Yes
Yes
No
2
67%
Carrier
Yes
Yes
Yes
3
100%
Other entity
Yes
Yes
No
2
67%
5
3
3
Did Entity Attempt to Provide
E-HM Information to
Emergency Responder?
“Yes” Totals by Simulation:
Totals
“Other” communication mechanisms used between the carrier and the responders and the other entity and responders was face-to-face verbal
communication.
73
Only successful attempts are included in totals.
74
The only electronic capability the driver had was a driver log terminal device. This device was unable to access HM shipping documents and
SDS information. The log terminal device was hard wired into the cab and could not be removed to share HM information (if such information
could be accessed via the device) with responders during emergencies.
72
Paperless Hazard Communications Pilot Project
63
5.3.2.3.1 Maritime Mode ER Simulations Data
The April 27, 2015 Maritime ER simulation (Simulation 19) e-HM communication devices, languages,
mechanisms, and formats used to communicate with emergency responders on-scene is provided in Table
20.
Table 20. Maritime (Simulation 19)—Devices, Electronic Data Exchange Languages, Communication Mechanisms, and
Electronic Data Formats Used to Communicate with Emergency Responders On-Scene
Device
Used by
Driver,
etc.
Received
by ER
PDAs
Workplace
computers
X
Used by
PSAP
Received
by ER
X
X
Landline telephones
X
Cellular phones
X
Smartphones
X
Live web cameras
X
Used by
Shipper
Received
by ER
Used by
Carrier
Received
by ER
Used by
Other
Received
by ER
X
X
X
X
X
X
X
X
X
Two-way radios
Data Exchange
Language
Unknown
Communication
Mechanism
Email
Direct device-todevice transmission
Internet
reference/link
Used by
Driver,
etc.
Received
by ER
Used by
PSAP
Received
by ER
Used by
Shipper
Received
by ER
Used by
Carrier
Received
by ER
Used by
Other
Received
by ER
X
X
X
X
X
Used by
Driver,
etc.
Received
by ER
Used by
PSAP
Received
by ER
Used by
Shipper
Received
by ER
Used by
Carrier
Received
by ER
Used by
Other
Received
by ER
X
X
X
X
X
X
X
X
X
X
X
Audio transmission
Other75
Electronic Data
Format
None, no electronic
data was exchanged
Unknown
75
Used by
Driver,
etc.
Received
by ER
X
Used by
PSAP
Received
by ER
Used by
Shipper
Received
by ER
Used by
Carrier
Received
by ER
Used by
Other
Received
by ER
X
X
X
X
“Other” communication mechanism used was face-to-face verbal communication.
Paperless Hazard Communications Pilot Project
64
5.3.2.3.2 Roadway Mode ER Simulation Data
The April 21, 2015 Roadway ER simulation (Simulation 20) e-HM communication devices, languages,
mechanisms, and formats used to communicate with emergency responders on-scene is provided in Table
21.
Table 21. Roadway (Simulation 20)—Devices, Electronic Data Exchange Languages, Communication Mechanisms, and
Electronic Data Formats Used to Communicate with Emergency Responders On-Scene
Used by
Shipper
Device
Workplace computers
Received by
ER
X
Used by
Carrier
Received by
ER
X
Used by Other
Received by
ER
X
Cellular phones
X
Tablets
Data Exchange
Language
Unknown
Communication
Mechanism
Email
Electronic Data Format
PDF
76
X
X
Used by
Shipper
Received by
ER
Used by
Carrier
Received by
ER
Used by Other
Received by
ER
X
X
X
Used by
Shipper
Received by
ER
Used by
Carrier
Received by
ER
Used by Other
Received by
ER
X
X
X
Used by
Shipper
Received by
ER
Used by
Carrier
Received by
ER
Used by Other
Received by
ER
X
X
X
5.3.2.3.3 Rail Mode ER Simulation Data
The May 6, 2015 Rail ER simulation (Simulation 21) e-HM communication devices, languages,
mechanisms, and formats used to communicate with emergency responders on-scene is provided in Table
22.
Table 22. Rail (Simulation 21)—Devices, Electronic Data Exchange Languages, Communication Mechanisms, and
Electronic Data Formats Used to Communicate with Emergency Responders On-Scene
Device
Used by
Driver, etc.
Received by
ER
Used by PSAP
Received by
ER
Used by
Carrier
Received by
ER
PDAs
Vehicle laptops
Workplace computers
Smartphones
X
X
X
Driver used cellular phone to call the terminal manager and gave the manager the officer’s email address. The terminal manager then emailed
the HM documents to the officer’s email address, and the officer assessed the HM information from the tablet.
76
Paperless Hazard Communications Pilot Project
65
Data Exchange
Language
Unknown
Communication
Mechanism
Email
Electronic Data Format
PDF
Used by
Driver, etc.
Received by
ER
Used by PSAP
Received by
ER
Used by
Carrier
Received by
ER
X
X
X
Used by
Driver, etc.
Received by
ER
Used by PSAP
Received by
ER
Used by
Carrier
Received by
ER
X
X
X
Used by
Driver, etc.
Received by
ER
Used by PSAP
Received by
ER
Used by
Carrier
Received by
ER
X
X
X
Paperless Hazard Communications Pilot Project
66
6. Impact Analysis Data
6.1 Description of Data Collection Activity and Volunteer
Participant Stakeholders
Concurrent with conducting the pilot tests, PHMSA collected impact analysis data from the HM
community during February 17, 2015 to May 15, 2015 to analyze the impacts of using e-systems for
communicating HM shipping paper information. Refer to Appendix N: Pilot Test Impact Analysis
Question Set for a copy of the Impact Analysis Question Set.
A total of 92 useable responses were received, including 82 fully completed question sets and 10 partially
completed question sets; these totals are reflected in Table 23. Approximately 41 percent of responses
were from inspectors and responders, with the majority of those being from the emergency responder
community. The other 59 percent of responses were from different segments of industry (shippers,
carriers, freight forwarders, HM trainers, equipment vendors, etc.).
Table 23. Impact Analysis Question Set Responses by Stakeholder Type
Responses
Fully
Completed
Stakeholder Type
Emergency Responders
Partially
Completed
Stakeholder
Percentage
Total
20
1
21
23%
HM Inspectors
Federal and State Governments
(undefined functions)
State/Local Governments—Emergency
Responders and HM Inspectors
5
0
5
5%
3
0
3
3%
8
1
9
10%
HM Shippers
7
1
8
9%
HM Carriers
18
2
20
22%
4
1
5
5%
1
0
1
1%
16
4
20
22%
82
10
92
100%
HM Shippers and Carriers
HM Shippers/Carriers and Emergency
Responders
Other (Freight Forwarders, HM Trainers,
Equipment Vendors, Software
Developers, Pipeline Transporters, HM
Manufacturers, Trade Associations,
LEPCs, Media, etc.)
Totals:
41%
59%
100%
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6.2 Impact Analysis Data
Tables in this section provide responses to wireless/e-communication/e-systems questions in the Impact
Analysis Question Set (refer to Appendix N: Pilot Test Impact Analysis Question Set).
Stakeholders provided answers listed in Table 24 when asked, “Has your agency/company/organization
ever used wireless or e-communication to provide law enforcement or emergency response personnel
with HM information for an HM shipment involved in an inspection or incident?”
Table 24. Use of Wireless or E-communication to Provide HM Information to Law Enforcement or Emergency Response
Personnel
Responses
Stakeholder Type
Yes
No
Unknown
Not Applicable
Emergency Responders
7
4
2
8
HM Inspectors
Federal and State Governments
(undefined functions)
State/Local Governments—Emergency
Responders and HM Inspectors
HM Shippers
2
0
0
3
0
1
0
2
4
1
1
3
1
5
1
1
HM Carriers
4
14
2
0
HM Shippers and Carriers
HM Shippers/Carriers and Emergency
Responders
Other (Freight Forwarders, HM Trainers,
Equipment Vendors, Software
Developers, Pipeline Transporters, HM
Manufacturers, Trade Associations,
LEPCs, Media, etc.)
3
1
0
1
0
1
0
0
4
6
5
5
Totals:
25
33
11
23
Stakeholders provided answers listed in Table 25 when asked, “Has your agency/company/organization
ever received wireless or e-communication of HM information for an HM shipment involved in an
inspection or incident?”
Paperless Hazard Communications Pilot Project
68
Table 25. Receipt of Inspection or Incident HM Information via Wireless or E-communication
Responses
Stakeholder Type
Yes
Emergency Responders
No
Unknown
Not Applicable
10
5
3
3
HM Inspectors
Federal and State Governments
(undefined functions)
State/Local Governments—Emergency
Responders and HM Inspectors
2
1
1
1
1
2
0
0
5
2
1
1
HM Shippers
0
7
1
0
HM Carriers
1
15
4
0
HM Shippers and Carriers
HM Shippers/Carriers and Emergency
Responders
Other (Freight Forwarders, HM Trainers,
Equipment Vendors, Software
Developers, Pipeline Transporters, HM
Manufacturers, Trade Associations,
LEPCs, Media, etc.)
2
2
1
0
0
1
0
0
3
8
4
5
Totals:
24
43
15
10
Stakeholders provided answers listed in Table 26 when asked, “Does your agency/company/organization
currently have an e-system capable of managing and communicating HM shipping paper information?”
Table 26. Agency/Company/Organization Currently Has E-System Capable of Managing and Communicating HM
Shipping Paper Information
Responses
Stakeholder Type
Yes
No
Unknown
Not Applicable
Emergency Responders
3
12
4
2
HM Inspectors
Federal and State Governments
(undefined functions)
State/Local Governments—Emergency
Responders and HM Inspectors
1
2
0
2
0
2
1
0
1
4
1
3
HM Shippers
1
7
0
0
HM Carriers
4
9
7
0
HM Shippers and Carriers
HM Shippers/Carriers and Emergency
Responders
Other (Freight Forwarders, HM Trainers,
Equipment Vendors, Software
Developers, Pipeline Transporters, HM
Manufacturers, Trade Associations,
LEPCs, Media, etc.)
2
3
0
0
0
1
0
0
7
4
2
7
Totals:
19
44
15
14
Paperless Hazard Communications Pilot Project
69
7. Data Evaluation
7.1 Stakeholder Group Findings
7.1.1
Shippers
As described in Section 3.3.1, all HM shippers are required to prepare hardcopy HM shipping papers for
HM that are in transport and provide them to carriers who will transport the HM. Many HM shippers
already have e-systems containing HM shipping paper information. Shippers are also required to provide
the HM shipping paper information to the carriers who will transport the HM.
7.1.2
Carriers
As described in Section 3.3.2, HM carriers are required to maintain the HM shipping paper when the HM
is in transport. Air, Maritime, and Rail Mode carriers have e-systems in place for communicating HM
shipping paper information, and most use EDI as the data exchange language because of their interaction
with the Rail Mode for intermodal transfers, as the Rail Mode requires e-HM shipping paper data be
provided to them in EDI format.
Transport of HM by roadway carriers is significantly different from their modal counterparts. The motor
carrier industry places importance of having an HM paper documentation trail (for billing purposes,
delivery receipts, driver payment records, etc.). Some trucking companies either cannot afford to purchase
an e-system or do not see a business reason to invest in one, and carriers would prefer that PHMSA
establish a performance standard for e-HM communication and keep the existing requirements for
hardcopy HM shipping papers. Implementation of e-systems may also be difficult for smaller motor
carrier companies that transport a wide variety of products; that do not have set delivery schedules; or that
make multiple stops on a transport route delivering various HM contained in trailers with multiple
compartments, because of the complexity of these HM shipments. Also, existing electronic and automatic
onboard recording devices do not function in some areas of the U.S. and Canada with Internet
connectivity dead spots; the same issue would likely exist for an e-system. Motor carriers who do not
have onboard technology are also concerned that they will be unable to provide e-HM information
directly and readily to inspection and emergency response personnel, scenarios that could delay
shipments; cause loss of revenue for the driver and the carrier, and potentially contribute to incident
liabilities.
An electronic means does not currently exist for the motor carriers to receive HM shipping documents
from, or to send HM shipping documents to, any of the other carrier modes.
7.1.3
Law Enforcement Inspectors
Paperless Hazard Communications Pilot Project
70
The HM law enforcement community consists of trained HM inspectors who are organized by
transportation mode. Regardless of mode, all HM inspectors will request a copy of the HM shipping
papers as part of the inspection process. Some inspectors, particularly those in the Air, Maritime, and Rail
Modes may not be equipped with electronic devices able to receive e-HM shipping paper information
while they are conducting HM inspections.
7.1.4
Emergency Responders
Section 3.3.4 describes the emergency responder stakeholder group as various professionals who are the
first to be notified of, and respond to, incidents involving HM. Some emergency response organizations
are volunteer-based, exist in rural areas with limited Internet connectivity, and are not provided with
electronic devices.
PSAP personnel training and professional experiences regarding HM vary greatly. Most PSAP personnel
are not familiar with the look and content of an HM shipping paper, and those at small rural PSAPs may
not know about placarding information.
Emergency responders need specific HM information immediately, based on the type of emergency and
the needed response. Responders indicated their capabilities regarding access to electronic information
varies; e-HM communication needs to be scalable; and they generally prefer to pull HM information from
its source rather than have it pushed to them. Accurate HM information is preferred over receiving quick,
unverified information, and responders want to have layered and redundant HM information systems, to
ensure responders can obtain the needed HM information as soon as possible. They also prefer to have a
link between the HM transportation conveyance and the e-HM shipping papers.
Emergency responders also desire a standard format and fields for e-HM information be created and
mandated, and that HM trade names be added as a required shipping paper field.
7.2 Performance of Pilot Test Paperless Hazard Communications
Systems
It is important to note that e-systems are still largely in the developing stages and that the data from the 21
pilot tests and the 92 impact analysis question sets completed by volunteer HM stakeholders constitute a
small, non-random sample of the HM transportation community. As such, it is not possible to draw
statistically valid conclusions from this limited data or to estimate costs and benefits with any quantitative
precision. Findings in this section should therefore be viewed as initial, qualitative insights on the types of
benefits and costs that may be associated with e-HM systems and their relative magnitudes and
importance to HM stakeholders. Benefit and cost impacts may also vary significantly by transportation
mode and by business type; for example, the impacts on Class I railroads may be very different from
those on owner-operator trucking firms. While the pilot tests and completed impact analysis question sets
allowed for some examination of differences by transportation mode and other characteristics, not all
organization types were necessarily represented.
Paperless Hazard Communications Pilot Project
71
7.2.1
E-communication Systems Used During Pilot Tests
Table 27 describes the e-communication systems, organized by time from initial request to receipt of HM
information, for each of the pilot test simulations.
Table 27. Pilot Test E-communication Systems
Simulation
Number
Time from
Request to
Receipt of HM
Information
17
Instantaneously
4
≤ 5 minutes
9
≤ 5 minutes
11
≤ 5 minutes
12
≤ 5 minutes
14
≤ 5 minutes
19
≤ 5 minutes
21
≤ 5 minutes
5
6 to 15 minutes
6
6 to 15 minutes
8
6 to 15 minutes
18
6 to 15 minutes
E-system Description
S/C contacted the ERO, who requested HM shipping paper information; the
S/C emailed a pdf copy of the shipping paper in XML to the responder’s
cellular/smartphone, PDA, and vehicle laptop computer; the local county
HM team were first to arrive at the scene.
Driver used cellular/smartphone to contact S/C; S/C used
cellular/smartphone/tablet to email pdf copy of shipping paper to LEIO’s
cellular/smartphone.
S/C used workplace computer to email a pdf copy of the shipping paper to
the LEIO’s workplace computer.
S/C used cellular/smartphone/PDA to email a pdf copy of the shipping
paper to the LEIO’s cellular/smartphone/PDA; LEIO was then able to print
a copy of the shipping paper.
S/C used cellular/smartphone/PDA to email a pdf copy of the shipping
paper to the LEIO’s cellular/smartphone and FAX machine.
Carrier used cellular/smart/landline phone and workplace computer to
email a pdf copy of the shipping paper in EDI language to the
ERO’s/LEIO’s workplace computer and cellular/smartphone.
Shipper contacted port patrol personnel, who arrived on scene first; port
PSAP dispatch used workplace computer, cellular/smartphone, and video to
email shipping paper in pdf format to port patrol personnel; PDAs and twoway radios were also used for audio communications.
Carrier field personnel arrived on-scene first, acted in a PSAP capacity, and
used PDA/smartphone to call ERO to report the incident; ERO used
smartphone to call CHEMTREC; CHEMTREC used workplace computer
to email a pdf copy of the shipping paper to the ERO’s smartphone and
workplace computer; ERO used smartphone/workplace computer to email
shipping paper to the carrier field personnel’s smartphone and I-Pad;
CHEMTREC then used landline phone to call shipper, and requested
shipper call ERO; shipper used smartphone to call ERO’s smartphone to
confirm shipping paper emailed by CHEMTREC was correct.
Driver used cellular/smartphone to contact S/C; S/C used
cellular/smartphone/tablet to email pdf copy of shipping paper to LEIO’s
cellular/smartphone.
Driver used cellular/smartphone to contact S/C; S/C used
cellular/smartphone/tablet to email pdf copy of shipping paper to LEIO’s
cellular/smartphone.
S/C used workplace computer to email a pdf copy of the shipping paper to
the ERO’s/LEIO’s vehicle laptop computer.
Port patrol personnel arrived on scene first, and contacted the police via
landline/cellular/smartphone; police officer then contacted the intermodal
yard rail coordinator via two-way radio/smartphone to request the HM
Paperless Hazard Communications Pilot Project
72
Simulation
Number
Time from
Request to
Receipt of HM
Information
1
16 to 30 minutes
3
16 to 30 minutes
7
16 to 30 minutes
16
16 to 30 minutes
20
16 to 30 minutes
2
31 to 60 minutes
10 (rural
roadway
inspection
simulation)
31 to 60 minutes
13
More than one hour
15
No time reported
E-system Description
shipping paper; intermodal yard rail coordinator emailed police officer the
HM shipping paper in jpeg format from his workplace computer/PDA, who
received the e-shipping paper via PDA/workplace computer; port
patrol/security received the e-shipping paper via PDA, workplace
computer, and cellular/smartphone.
Driver used cellular/smartphone to contact S/C; S/C used
cellular/smartphone/tablet to email pdf copy of shipping paper to LEIO’s
cellular/smartphone.
Driver used cellular/smartphone to contact S/C; S/C used
cellular/smartphone/tablet to email pdf copy of shipping paper to LEIO’s
cellular/smartphone.
Carrier used cellular phone to contact its dispatcher, who used a workplace
computer to email a pdf copy of the shipping paper to the LEIO’s
cellular/smartphone.
Shipper used workplace computer to email a pdf copy of the shipping paper
to the inspector’s workplace computer.
Fire personnel arrived on-scene first; driver used cellular phone to call
terminal manager and request the HM shipping paper; terminal manager
used cellular phone to call carrier and request permission to send HM
shipping paper to driver; carrier granted permission, so terminal manager
emailed a pdf copy of the shipping paper to the driver’s cellular phone;
driver then emailed the pdf shipping paper to the fire emergency
responder’s tablet.
Driver used cellular/smartphone to contact S/C; S/C used
cellular/smartphone/tablet to email pdf copy of shipping paper to LEIO’s
cellular/smartphone.
Shipper attempted to use landline phone, CAD terminal, and vehicle laptop
to send e-shipping papers to inspector’s cellular phone and vehicle laptop
computer, but was unsuccessful; shipper and inspector moved locations
multiple times to attempt to get electronic connectivity; shipper emailed a
pdf copy of the shipping paper to the inspector’s vehicle laptop computer
and CAD terminal.
Shipper was contacted by LEIO via cellular phone, contact was made
outside of shipper’s normal hours of business, and shipper was not set up
for e-shipping paper transfer outside of normal business hours during pilot
test; shipper faxed a pdf copy of the shipping paper to the LEIO’s vehicle
laptop computer and office FAX machine
LEIO called the terminal using a landline phone to request the HM
shipping paper; terminal personnel emailed a pdf copy of the shipping
paper to the inspector’s workplace computer
Paperless Hazard Communications Pilot Project
73
7.2.1.1
Evaluation of Pilot Test E-communication Systems by Time for HM Data Receipt
Inspectors and emergency responders want to receive accurate and complete HM information as soon as
possible, preferably within five minutes from time of request. The eight simulations (38%) where
inspectors/emergency responders received the HM information instantaneously or within five minutes or
less (i.e., Simulations 17, 4, 9, 11, 12, 14, 19, and 21) used cellular and smartphones, tablets, PDAs,
laptop computers, and/or workplace computers to send and receive the e-HM information. These
inspectors and emergency responders reported that the e-information matched that on the hardcopy
shipping papers and accurately reflected the HM being transported.
The four simulations (19%) where inspectors/emergency responders received the HM information within
6 to 15 minutes (i.e., Simulations 5, 6, 8, and 18) and the five simulations (24%) where the HM
information was received within 16 to 30 minutes (i.e., Simulations 1, 3, 7, 16, and 20) used landline,
cellular, and smartphones, two-way radios, tablets, PDAs, laptop computers, and/or workplace computers
to send and receive the e-HM information. One reason for the delay in receipt of the HM information was
the multiple entities that were contacted for granting permission to provide the requested HM information
to the simulation participants.
Simulations 2, 10, and 13 (14%) took at least 31 minutes for inspectors/emergency responders to receive
the requested HM information. Reasons for the information receipt delay included lack of Internet
connectivity (rural area) and request was made outside of shipper’s normal hours of business.
No time was reported for the receipt of the HM information for Simulation 15 (5%).77
7.2.2
Pilot Test Inspectors’ Feedback on the Inspection Simulations
Inspectors who participated in the pilot test simulations provided the simulation feedback information in
this section.
7.2.2.1
Validity and Accuracy of HM Inspection Simulation Information
The thirteen roadway and three maritime inspectors who reported the inspection simulation HM
information was transmitted electronically indicated they checked the validity of the e-HM information
received by comparing it with the hardcopy HM shipping paper/bill of lading/Dangerous Goods
Declaration, the physical HM packaging, and/or the HMR (49 CFR 172). All 15 inspectors found that the
e-HM information they received matched the information recorded on the hardcopy documents and
accurately reflected the details of the HM being transported.
77
PHMSA attempted to contact this inspector to obtain the HM information receipt time, but was informed that the inspector has transferred to a
new location and was unreachable for comment. In addition, no vetted shipper or carrier was involved in this simulation, so PHMSA could not
contact a shipper or carrier to obtain this information.
Paperless Hazard Communications Pilot Project
74
Twelve of the roadway inspectors (92%) thought the information included within the e-transmittal was
sufficient to determine a passed or failed inspection; the one roadway inspector (8%) who felt the
information included within the e-transmittal was insufficient to determine a passed or failed inspection
reported that the e-data needed to be delivered in a timely manner (i.e., during the actual inspection
simulation).
Two of the maritime inspectors (67%) thought the information included within the e-transmittal was
insufficient to determine a passed or failed inspection. These inspectors reported that additional
information regarding physical vessel inspections, compliance with 49 CFR HM shipping regulations,
and additional container and cargo inspection details (structure details, placarding, proper stowage and
marking of cargo, etc.) was needed to determine a pass or fail rating. Some of this additional information
can only be verified by a visual inspection of the container and cargo, and would not be found on an HM
shipping paper.
Eleven roadway inspectors (85%) and two maritime inspectors (67%) felt the e-information received fully
satisfied the HM information currently required to be provided as paper documentation, two roadway
inspectors (15%) felt the e-information received partially satisfied the current HM paper-required
documentation, and one maritime inspector (33%) felt the e-information mostly satisfied the current HM
paper-required documentation. Additional HM information the three inspectors felt was needed to fully
satisfy HM inspection needs included:
Timely delivery of e-data (this inspection was over before the e-data was delivered);
Vessel inspection information for compliance with 49 CFR HM shipping regulations78; and
Inspection information related to container structure and placarding and proper cargo stowage,
blocking, bracing, packaging, marking, and labelling79.
7.2.2.2
Impact of E-systems on Inspection Completion Times
When asked about their thoughts on how e-HM systems will affect the time needed to conduct
inspections, the pilot test inspectors provided the responses listed in Table 28.
Table 28. E-systems' Impact on Inspection Times
Roadway Simulations
E-systems’ Impact on Inspection
Times
Maritime Simulations
Total
(all Inspection
Simulations)
Count
Percentage
Count
Percentage
Count
Percentage
Positive
1
8%
1
33%
2
12.5%
Negative
10
76%
0
0%
10
62.5%
No impact
1
8%
1
33%
2
12.5%
78
79
This information is not one of the required 49 CFR 172.202 shipping paper HM descriptions.
Ibid.
Paperless Hazard Communications Pilot Project
75
Roadway Simulations
Other:
Roadway inspector believes esystems will negatively affect the
time to conduct inspections in
rural areas (negative impact)
Maritime inspector believes esystems will provide a safer and
quicker means of exchanging
HM information (positive
impact)
1
8%
Total
(all Inspection
Simulations)
Maritime Simulations
1
33%
2
12.5%
(6.25%
positive,
6.25%
negative)
Of the ten “negative” roadway responses, seven were from the same inspector (LEIO ID 19), who
reported for the seven inspection simulations inspection completion times of less than five minutes to up
to 30 minutes; the e-information fully satisfied inspection information needs; and no impediments or
limitations were identified during the simulations. Another inspector who answered “negative” (LEIO ID
18) reported the extensive preparation time needed to arrange the simulation; the time spent actually
conducting this simulation was “less than 5 minutes.” Another inspector who answered “negative” (LEIO
ID 17) reported a total inspection time of 4 hours, 3 minutes, but cited the reasons for this lengthy time
period as the e-HM information was requested outside of the shipper’s normal e-system business hours,
so multiple staff had to be contacted for the information. The remaining inspector who answered
“negative” (ERO/LEIO ID 15) reported it took ten minutes to receive the requested e-HM information via
email.
7.2.2.3
Benefits Associated with E-systems and Associated Components
When asked as to what benefits an e-system would offer over the current paper-based system, pilot test
simulation inspectors reported the information in Table 29.
Table 29. E-system Benefits over Current Paper-Based System
Roadway Simulations
Maritime Simulations
Count
Percentage
Count
Percentage
Reduced staff time and/or cost to prepare shipping
papers
1
8%
1
33%
Reduced costs for transfer between modes or carriers
1
8%
0
0%
Reduced error rate in data entry
1
8%
1
33%
Ease of data entry
0
0%
1
33%
Reduced costs for hardcopy storage and retrieval
1
8%
0
0%
Faster transport times for shipments
0
0%
0
0%
Improved customer satisfaction
1
8%
0
0%
E-System Benefits (vs. Paper HM Documentation)
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Roadway Simulations
Maritime Simulations
Reduced insurance or risk management costs
0
0%
0
0%
No benefits
12
92%
2
67%
Other:
Quicker access to sharing of information with
mutual aid emergency responders entering the
port to assist in responding to HM incidents
0
0%
1
33%
Total Responses80:
Roadway: 17
Maritime: 6
One of the 13 roadway inspectors (8%) and two maritime inspectors (67%) indicated they found e-system
components beneficial to HM communication. These inspectors identified the following benefits related
to e-system components:
Benefits regarding electronic/wireless devices used (100%);
Benefits associated with the data language (e.g., XML, EDI, etc.) used (33%);
Benefits in the communication mechanism (e.g., email, Internet reference/link, etc.) utilized
(33%);
Benefits associated with the data format (e.g., pdf, jpeg, etc.) used (33%); and
Benefits associated with the time required to receive the shipping paper information (100%).
7.2.2.4
E-system Impediments/Limitations Identified During Inspection Simulations
Five of the thirteen roadway inspectors (39%) identified e-system impediments/limitations, while the
three maritime inspectors did not identify any e-system impediments/limitations. The five roadway
inspectors identified the following e-system impediments/limitations:
Lack of timely electronic access in rural areas (20%);
Problems with electronic/wireless devices (difficult to verify information on a small screen, and
image was upside down) (20%);
Problems with the communication mechanism (e.g., email, Internet reference/link, etc.) (20%);
Problems with the data format (e.g., pdf, jpeg, etc.) (20%);
Communication issues between driver and dispatcher (assumption that e-data had already been
received by the inspector; some shipper/carrier e-systems not set up for 24 hours/day, 7
days/week transfer of data) (20%); and
Limited dispatch assistance due to heavy workload of dispatcher (20%).
7.2.2.5
Training Needs for Conducting Transfers of E-HM Inspection Information
Three of the thirteen roadway inspectors (23%) and two of the three maritime inspectors (67%) believe
training on the following is needed to conduct electronic transfers of HM inspection information:
80
Drivers need to know inspectors will ask for DOT shipping paper information for HM carried in
the vehicle to be sent immediately upon request;
These totals represent the sum of all individual benefits provided, not the total number of inspectors providing a response.
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The process inspectors should use to receive the e-information, including how to request the einformation in the event of injury or death to the driver;
Dispatchers receiving the e-information need to be trained on the HM information requirement
and on the process to relay the needed information to the inspectors/emergency responders;
While some ports are in the process of updating port officers’ vehicle computer Wi-Fi capabilities
to include better coverage areas, not all port officers are issued smart type phones capable of
getting e-information. Training is needed on how to maintain port inspection officers’ safety in
areas of the port with high volume of moving heavy equipment while having a quicker means of
communicating with long shore foreman to determine the exact location of a specific HM
container/truck within the port;
Use of correct terminology to ensure the correct documentation is sent electronically; and
Training on how to correct HM paperwork.
7.2.2.6
Equipment Needs for Conducting Transfers of E-HM Inspection Information
All thirteen roadway inspectors (100%) indicated no additional equipment is needed to conduct e-HM
information transfers, while one of the three maritime inspectors (33%) recommended that port Wi-Fi
connectivity needs to be updated, and inspection officers need to have emergency response guidebook
access immediately at all times when conducting port HM inspections.
7.2.2.7
Lessons Learned Information for Improving the Use of E-HM Shipping Papers
Three of the thirteen roadway inspectors (23%) and one of the three maritime inspectors provided the
following “lessons learned” information for improving the use of e-HM shipping papers in commerce:
Send HM shipping papers to the investigator on-site and to a command post via email, fax, or
smartphone;
Regulations need to define the amount of time the shipper/carrier has to provide the e-HM
shipping paper information before a violation for accessibility of the information would be
documented, with considerations for significant monetary penalties for non-compliance and
keeping the vehicle in out-of-service status until the information is provided;
E-HM information received during one roadway inspection simulation was via email of a pdf
shipping paper; which took 10 minutes from request to receive. Such scenarios have the potential
to increase inspection times instead of streamlining; and
Ensure and maintain liaison with longshore workers when doing maritime HM inspections. They
are the experts in the field on where the particular HM container/vessel/truck is located and can
provide quick specific HM location information.
7.2.3
Pilot Test Emergency Responders’ Feedback on the ER Simulations
Emergency responders who participated in the pilot test simulations provided the simulation feedback
information in this section.
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7.2.3.1
Validity and Accuracy of HM Emergency Response Simulation Information
The emergency responders who participated in the five ER simulations indicated they checked the
validity of the e-HM information received by comparing it with the hardcopy HM
documentation/Dangerous Goods Declaration and/or the physical HM packaging. All emergency
responders found that the e-HM information they received matched the information recorded on the
hardcopy documents and accurately reflected the details of the HM being transported.
Emergency response entities for all five ER simulations (100%) reported that the information included
within the electronic transmittal was sufficient, and equivalent to the hardcopy shipping paper, to identify
the hazards and properly respond to the HM simulated incident. Four emergency response entities (80%)
felt the e-information received fully satisfied the HM information currently required to be provided as
paper documentation. One (20%) felt the e-information partially satisfied the current HM paper-required
documentation, and reported that the driver’s lack of a removable electronic device in the truck cab that
could access the e-HM shipping paper information was the reason for this rating.
7.2.3.2
Impact of E-systems on Emergency Response Times
When asked about their thoughts on how e-HM systems will affect the time needed to respond to an HM
incident, the pilot test emergency responders provided the responses listed in Table 30.
Table 30. E-systems' Impact on Emergency Response Times
Emergency Response Simulations
E-systems’ Impact on Emergency Response Times
Count
Percentage
Positive
3
60%
Negative
0
0%
No impact
0
0%
Other:
Benefit would be positive unless incident happened in a dead zone
(positive impact)
Response times would not change, but having quicker access to HM
information may increase safety for first responders (neutral impact)
2
40%
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7.2.3.3
Benefits Associated with E-systems and Associated Components
When asked as to what benefits an e-system would offer over the current paper-based system, pilot test
simulation emergency responders reported the information in Table 31.
Table 31. E-System Benefits over Current Paper-Based System
Emergency Response
Simulations
E-System Benefits (vs. Paper HM Documentation)
Count
Percentage
Reduced staff time and/or cost to prepare shipping papers
3
60%
Reduced costs for transfer between modes or carriers
3
60%
Reduced error rate in data entry
2
40%
Ease of data entry
1
20%
Reduced costs for hardcopy storage and retrieval
3
60%
Faster transport times for shipments
0
0%
Improved customer satisfaction
3
60%
Reduced insurance or risk management costs
1
20%
No benefits
0
0%
Other:
Reduced time to receive hazard information for quicker
decisions on protective actions
Quicker and more accurate information for port and outside
mutual aid emergency responders
Capability for multiple devices to access HM information
versus one hardcopy, thus providing quick technical
assistance to response units
Quicker access for on-scene responders, thus providing a
better and safer response
4
80%
Total Responses:81
20
Three of the emergency response entities (60%) indicated they found the following e-system components
beneficial to HM communication:
81
Benefits regarding electronic/wireless devices used (100%);
Benefits associated with the data language (e.g., XML, EDI, etc.) used (33%);
Benefits in the communication mechanism (e.g., email, Internet reference/link, etc.) utilized
(100%);
Benefits associated with the data format (e.g., pdf, jpeg, etc.) used (67%);
Benefits associated with the time required to receive the shipping paper information (100%);
This total represents the sum of all individual benefits provided, not the total number of emergency responders providing a response.
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Benefits of quickly receiving the information electronically versus having to contact the port
intermodal tower and request that the staff locate hardcopy documentation (33%); and
Benefits associated with an external fire department’s capability to quickly review and
immediately share e- HM information during a response to an actual emergency (33%).
7.2.3.4
E-System Impediments/Limitations Identified During Emergency Response
Simulations
Two of the emergency response entities (40%) identified the following e-system impediments/limitations:
Parts of original document were not legible and thus were hard to read (33%); and
Driver had no carrier-supplied electronic device that could be removed from cab and that had the
capability to receive or store e-HM shipping documents. In addition, the majority of fire service
field units do not have department assigned tablets and Internet connectivity that can receive eHM documents (33%).
7.2.3.5
Training Needs for Conducting Transfers of E-HM Emergency Response
Information
Three emergency response entities (60%) indicated responders need the following training to conduct
electronic transfers of HM emergency response information:
How to decipher and understand e-information,
How to use new port electronic capabilities, including how to access and print e-HM information
at remote location (e.g., in vehicles); and
Training for department personnel who are responsible for purchasing and assigning devices with
e-capabilities.
In addition, these three emergency response entities recommended that responders receive additional
training on the Emergency Response Guidebook82, to better equip them to respond safely and effectively
to HM emergencies.
7.2.3.6
Equipment Needs for Conducting Transfers of E-HM Emergency Response
Information
Four emergency response entities (80%) believe the following additional equipment is needed to conduct
ER e-HM information transfers:
82
Smartphones or other devices capable of receiving, reading, and transmitting pdf documents;
Mobile data terminals (MDTs)/laptops/toughbook/tablets with Internet connectivity capability
and preferably portable/removable in vehicle, possibly with printers, to allow on-site generation
of hardcopy HM documentation; and
Increase built-in capabilities for internal report generation in information management systems.
An electronic version of the 2012 Emergency Response Guidebook can be found at http://www.phmsa.dot.gov/hazmat/library/erg.
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7.2.3.7
Lessons Learned Information for Improving the Use of E-HM Shipping Papers
Three emergency response entities (60%) provided the following “lessons learned” information for
improving the use of e-HM shipping papers in commerce:
Ensure HM documentation provided via FAX is legible;
Ensure a process is in place for quick access to hardcopy documents, as a backup in instances
where Internet/power capabilities are compromised; and
PSAP centers should be able to receive the HM documents from the carrier quickly and be able to
transmit via current dispatch devices on most response vehicles. If the information is being
transmitted verbally, the dispatcher personnel will require training on shipping documents and
SDSs.
7.2.4
Additional Pilot Test Findings
E-systems are still largely in the developing stages, and the data from the 21 pilot tests and the 92 impact
analysis question sets completed by volunteer HM stakeholders constitute a small, non-random sample of
the HM transportation community. While it is not possible to draw statistically valid conclusions from
this limited data or to estimate costs and benefits with any quantitative precision, the following general
observations can be made from the pilot test data:
The most frequently used devices to send and receive HM data electronically were landline,
cellular, and smartphones, two-way radios, tablets, PDAs, laptop computers, and workplace
computers. These devices were used in all 21 pilot test simulations, and resulted in receipt of the
HM information within five minutes in 8 of the 21 (38%), and within 15 minutes in 12 of the 21
(57%), simulations. These devices appear to be good candidates for investment by HM
stakeholders to share electronic HM information.
A pdf format of the shipping paper was used in all 21 pilot test simulations. This format was able
to be read by all the pilot test inspectors and emergency responders who received the electronic
HM information. Regardless of data language used, pdf format appears to be send-able,
receivable, and readable on the recommended devices in the previous bullet.
Some pilot test inspectors and emergency responders had difficulty reading the HM data on their
cellular/smartphones, due to the small screen size of the device, the image being presented upside
down, and parts of the original hardcopy document being illegible and thus hard to read in the
emailed pdf document.
Delays in receipt of electronic HM data may be caused by requests generated during
shippers’/carriers’ non-business hours and by permission needs from senior staff/other entities
before a stakeholder can electronically transfer the requested HM information.
Five of the eight pilot test inspectors (63%) felt that e-systems will have a negative effect on
inspection times. The time for receipt of the requested electronic HM data in nine of these
inspection simulations (82%) ranged from less than 5 to 30 minutes. In addition, four of the five
roadway (80%) and two of the three maritime (67%) pilot test inspectors identified that an esystem offers no benefits over the current paper-based system. These negative perceptions may
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result from the routine nature of inspections, where many are conducted based on a set frequency
rather than to address an emergency situation.
Four of the five pilot test emergency responders (80%) felt that e-systems will have a positive
effect on inspection times, and the fifth pilot test emergency responder indicated that having
quicker electronic access to HM information may increase safety for response personnel. All five
pilot test emergency responders (100%) identified benefits an e-system offers over the current
paper-based system. The positive perceptions of this stakeholder group regarding the use of esystems may result from their need to access HM information immediately to respond to
emergencies, and that any method that can potentially provide accurate HM information quickly
while maintaining and enhancing responders’ safety is beneficial.
7.3 Safety and Security Impacts of Using E-systems
An assessment of the safety and security impact of using e-systems, including any impact on the public,
emergency response, law enforcement, and the execution of inspections and investigations, is provided in
this section.
The e-system concept requires at least an equivalent level of safety and security as compared to the
current hardcopy-based system of hazard communication. Some e-systems may also be able to provide
improved safety by increasing the accuracy and timeliness of information received by first responders,
notably for information such as commodity, hazard class, quantity, container type, and emergency contact
number, as long as procedures are in place to verify the accuracy of the HM data when it is first entered
into the e-system. In addition, obtaining HM information electronically rather than having to approach a
transportation conveyance involved in an emergency situation may improve safety for responders and
improve the effectiveness of their efforts.
E-systems that have been verified and tested as being protected from unauthorized access may also
provide better security of HM information, by requiring vetted users to provide user authentication
information prior to gaining access to HM information. Because e-systems allow for HM information to
be maintained electronically, the possibility of HM shipping documents being lost or damaged can be
reduced. E-systems that have redundancy capabilities are also potentially more robust than hardcopy
shipping papers in the event of an incident, since conventional hardcopy shipping papers are susceptible
to fire damage during an incident or may otherwise be inaccessible to the first responders. Without this
information, emergency response may be less effective and incident consequences may be more severe in
terms of property damage and injuries.
At the current state of development, not enough real-world data on the performance of e-systems exists to
be able to characterize their performance or quantify safety and security benefits relative to the current
hardcopy-based system. However, several pieces of evidence are available to provide some insight into
potential safety and security impacts.
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7.3.1
Evidence from Incident Data
PHMSA conducted a review of PHMSA incident data83 covering the period from 2009 to 2011 to
understand the prevalence of impaired hazard communication in serious HM incidents. Based on that
review, scenarios involving serious incidents with impaired hazard communication appear to be very rare
in comparison to the volume of shipments, but they do occur.84 Generally, these communication failures
can be viewed in three categories: (1) cases where there was no HM information, such as with undeclared
shipments; (2) cases where the relevant information was damaged or destroyed during the incident, such
as during a fire; and (3) cases where the HM information was incomplete or incorrect and/or necessitated
additional steps (such as multiple phone calls) to get full details to emergency responders. The following
incident narrative excerpts provide some examples of these issues:
“Due to the damage done to the packages due to heat and fire, nothing was identifiable on them
as far as packaging information.”85
“Shipper did not correctly state chemical and after 3 tries provided us with correct (M)SDS.”86
“Per the telephonic PHMSA report sent to me it advised that the truck was hauling 300 pounds of
a corrosive material and an undetermined amount of flammable liquid. There was in fact no
corrosive material onboard the trailer.”87
While electronic hazard communication would not eliminate each of these issues, it could reduce their
likelihood and/or impact. For example, keeping all information electronically, preferably in redundant esystems, reduces the possibility that HM shipping documents will be lost or damaged, and software
interfaces can help reduce misspellings of chemical names and other sources of error, if procedures and
processes for ensuring the HM data is entered correctly into the e-system are in place. In the case of a
serious vehicle crash or fire, the ability to obtain HM information electronically—and without having to
approach the vehicle—may improve safety for responders and improve the effectiveness of their efforts.
All of these impacts would tend to improve incident response and reduce the direct costs incurred by HM
shippers and carriers. However, the magnitude of all these impacts is difficult to quantify until more
operational experience is gained with e-systems. Most e-systems would also have their own limitations,
such as occasional system outages or telecommunications problems, that would need to be taken into
account when estimating the potential safety and security impacts.
83
PHMSA OHMS Incident Report Database, https://hazmatonline.phmsa.dot.gov/IncidentReportsSearch/IncrSearch.aspx.
The study team analyzed incident records for the 3-year period from 2009 to 2011. During this period, there were 44,627 incidents, of which
1,418 met one or more PHMSA criteria to be considered a “serious” incident. Of these, the study team identified 92 highway incidents in which
hazard communication may have been impaired, based on the incident data and accompanying narrative.
85
Incident record E-2009040317, 04/21/2009 in Woodstock, VA.
86
Incident record I-2011090314, 09/02/2011 in Ringgold, GA.
87
Incident record E-2010050343, 01/13/2010 in Williams, AZ.
84
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7.3.2
Other Considerations
Other safety and security considerations regarding the impacts associated with the use of e-systems
include:
Impacts associated with outages or telecommunications problems;
Impacts if e-system is hacked, and associated HM data is compromised/altered/deleted;
Authorized users will need to be identified, notified, vetted, and trained on the e-system; and
Access to some e-systems, especially those that involve multiple stakeholder types, will need
password-protection, encryption, or other security access measures to allow access only to
authorized users.
7.4 Benefits and Cost Considerations
The benefits of-e-systems can be divided into two key areas: public safety benefits and administrative
cost savings. Safety benefits are predicated on the idea that paperless hazard communication, by
improving the timeliness and quality of the information available to emergency responders, could help to
mitigate the consequences of HM incidents, leading to reduced injuries, property damage, environmental
damage, and other costs. These benefits would apply to HM shippers and carriers in the form of reduced
cargo losses and liability exposure, and to the general public in terms of reduced fatalities and injuries.
HM shippers and carriers would realize administrative cost savings primarily in the form of reductions in
the expenses currently associated with generating hardcopy HM shipping papers, transferring this
information between shippers and carriers, maintaining it during transport, and storing and retrieving
these records.
7.4.1
Public Safety Benefits
7.4.1.1
Evidence from the 92 Impact Analysis Question Set Responses
Of the 92 respondents to the impact analysis question set, 25 reported having used wireless or ecommunication at least once to convey HM shipment information to law enforcement or emergency
responders. A slightly smaller number, 21 respondents, reported having an e-system that could manage
and communicate HM shipping paper information; in answering a question regarding the impacts and
benefits of their e-HM systems, these respondents largely cited operational efficiencies and cost savings
but also noted the potential for security- and safety-related benefits. In particular, 60% of those
responding (9 of 15) stated that their e-HM system provided “faster delivery of HM information to
emergency responders” and “more accurate HM data for emergency preparedness and response.” These
responses, while limited to the respondents’ subjective impressions, indicate that a majority of
respondents with actual experience using an e-system believe the e-system provides relevant safetyrelated advantages compared to the current paper-based system. These findings cannot be generalized to
the broader HM shipper and carrier community due to the small sample size, but they are indicative of the
potential for benefits in these areas.
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7.4.1.2
Evidence from the Pilot Test Simulations
Nineteen percent of inspectors and eighty percent of emergency response organizations who participated
in pilot test simulations noted positive impacts on inspection and emergency response times. Refer to
Sections 7.2.2.2 and 7.2.3.2 for additional information.
7.4.2
Administrative Cost Savings
In analyzing potential administrative cost savings and business process impacts, it is important to make
the distinction between electronic hazard communication and the broader concept of electronic commerce
(e-commerce). E-commerce refers to a business model whereby a firm is able to conduct a broad range of
business functions over an electronic network; for example, by replacing hardcopy business records and
manual processes with e-data exchanges. By contrast, electronic hazard communication refers only to the
transfer of hazard communication via electronic means rather than through conventional shipping papers.
While an e-commerce approach might include an electronic hazard communication component, it is also
possible to implement electronic hazard communication without converting other business processes to
electronic means. For example, an HM shipper could implement electronic hazard communication while
still sending paper-based invoices to customers and suppliers and using paper-based records for inventory
and other business functions. This distinction is important because the benefits that are specific to
electronic hazard communication need to be analyzed separately from the wider range of benefits that
might accrue from a broader transition to e-commerce.
7.4.2.1
Evidence from Literature Review
Unfortunately, while there is ample information in the literature on e-commerce initiatives in the freight
industry, there is little information on the specific business impacts of electronic hazard communication.
The best available information comes from the Hazardous Materials Cooperative Research Program,
Report 8, which analyzes the prospects for electronic shipping papers in HM transportation.88 Based on
interviews with industry stakeholders, Report 8 notes that electronic hazard communication would
produce administrative cost savings in data entry, particularly for shipments that use multiple modes or
carriers, since the required data only has to be entered once. This aspect also reduces data-entry errors and
associated delays. In addition, stakeholders identified the potential for reduced costs related to handling,
tracking, filing, storing, and retrieving hardcopy shipping papers. Estimates of time savings ranged
widely, from just a few minutes per HM shipment to up to one hour or more saved per shipment. The
authors of Report 8 were not able to identify the reasons for this very wide range of potential
administrative time savings.
7.4.2.2
Evidence from the 92 Impact Analysis Question Set Responses
Responses to the impact analysis question set largely confirm the initial findings from Report 8 with
regard to administrative cost savings. Among respondents who use an e-HM system and responded to a
88
Transportation Research Board, Hazardous Materials Cooperative Research Program (HMCRP), Report 8, Evaluation of the Use of Electronic
Shipping Papers for Hazardous Materials Shipments, 2012 (http://onlinepubs.trb.org/onlinepubs/hmcrp/hmcrp_rpt_008.pdf).
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question on impacts and benefits, 87% reported that the system led to “increased operational efficiency,”
and 67% reported “reduced staff time and/or cost to prepare shipping papers. Slightly smaller numbers
reported other benefits, such as reduced costs of hardcopy storage and retrieval (60%), as shown in
Error! Reference source not found.. The breakout of responses was fairly similar between HM shippers
nd carriers and across firms of different sizes.
Figure 1. Benefits of E-systems
“What benefits does the e-system offer over a paper-based system? Please select all that apply.”
Increased operational efficiency
Reduced staff time and/or cost to prepare shipping…
Improved regulatory compliance
More accurate HM data for emerg. prep. & response
Faster delivery of HM information to emergency…
Reduced costs for hardcopy storage and retrieval
Improved customer satisfaction
Ease of data entry
Reduced error rate in data entry
Reduced costs for transfer between modes or carriers
More efficient HM tracking and locating
Improved HM inspection data
Decreased time needed for HM inspections
Improved HM data security
Reduced insurance or risk management costs
Faster transport times for shipments
Unknown
No benefits 0%
87%
67%
60%
60%
60%
60%
53%
53%
53%
47%
40%
40%
33%
27%
27%
27%
13%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
By contrast, a relatively small share (27%) of respondents stated that their e-system was leading to
outright shorter transport times for shipments. This outcome suggests that the benefits of the e-system
may be much more common in administrative areas such as shipping paper preparation, regulatory
compliance, and hardcopy retrieval and storage, rather than in operational areas such as vehicle
utilization, driver/operator labor costs, and fuel use. However, for the firms who are able to achieve
savings in transit times, the savings could be significant and lead to broader benefits through the supply
chain, such as lower inventory costs.
One benefit area for which benefits can be quantified somewhat further is in the preparation of shipping
papers, which was cited as a benefit by 67% of e-HM users. Impact analysis question set respondents
provided information on the time required to prepare hardcopy HM shipping papers under the current
system and the time required to prepare e-shipping papers using their e-system. For the hardcopy
approach, the median response was just over ten minutes; for the e-system approach, the median response
was about five minutes, indicating a rough average of five minutes saved per shipping paper produced.
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The reduction in time required was more pronounced for shippers than for carriers, and for larger firms
than for small firms, but each category registered an average decrease. In very rough terms, a five-minute
savings per shipping paper is the equivalent of approximately $1.80 in labor cost savings per shipment,
based on Bureau of Labor Statistics data.89 Actual cost savings would vary, potentially significantly,
across different organizations, industries, and e-system formats. The 92 impact analysis question set
responses do not provide enough detail with which to estimate those varying impacts; however, at the
economy-wide level, the existence of 800,00090 to 1.2 million91 daily HM shipments in the U.S. would
mean that the benefits could be substantial.
7.4.2.3
Evidence from the Pilot Test Simulations
Administrative cost benefits identified by pilot test participants include:
Reduced staff time and/or cost to prepare shipping papers;
Reduced error rate in data entry;
Ease of data entry; and
Reduced costs for hardcopy storage and retrieval.
Refer to Sections 7.2.2.3 and 7.2.3.3 for additional details.
7.4.3
E-System Implementation Costs
Moving from the current paper-based system to an e-system may entail substantial transition costs. Report
8 notes that stakeholders expressed concerns regarding the capital and recurring costs associated with
converting to e-HM. These could include technology hardware and software costs, licensing, and
upgrades, as well as one-time and ongoing costs for training on the new e-system. In addition, costs
associated with customer outreach and education need to be considered; these costs could rise if the esystem were to completely replace, rather than supplement, the existing paper-based HM shipping paper.
Conversion to an e-HM approach will likely be less costly for shippers and carriers that are already using
an EDI system and will provide more immediate business benefits in terms of reduced administrative
costs.
7.4.3.1
Evidence from the 92 Impact Analysis Question Set Responses
The impact analysis question set provides limited insight into cost issues due to the small number of
respondents who had a fully operational e-system and thus could respond to questions about development
costs. Of the 21 respondents with some form of e-system, only ten reported the system to be at
Technology Readiness Level 5, i.e., fully operational in real-world environment. Of those ten, all but one
respondent either did not have, or preferred not to share, information on the costs to “develop, implement,
operate, and maintain” the e-HM system. Estimates of the amount of money invested to date in the e89
Based on BLS Occupational Employment Statistics, May 2015. The average hourly wage for an illustrative job series (cargo/freight agent, 435011) and industry (freight transportation arrangement, NAICS 488500) is $21.56.
90
Estimate from Hazardous Materials Shipments, USDOT/RSPA, 1998
(http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/hmship.pdf).
91
Estimate was provided via conversation with CHEMTREC staff in 2012 and was based on 2011 HM shipments.
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system ranged from $25,000 to $2.5 million.
In addition to information technology and other system development costs, another key cost item is
training for employees on the e-system. While none of the impact analysis question set respondents were
able to provide direct estimates of the associated training costs, 65% of respondents with functioning esystems said that employees received initial training on the e-system, suggesting that it is not an
uncommon implementation element. The reported length of training varied, with the most common
response being “less than two hours” (39%), though that was followed closely by “more than eight hours”
(23%). The number of employees who receive training also varied, with some respondents noting that it
involved thousands of employees. Ten respondents also stated that employees receive refresher training,
with the most common frequency being annual. Customer outreach and education is another potential cost
item for organizations transitioning to e-systems, since the move to an e-system may require adjustments
to business practices and customer interfaces. However, only 10% of impact analysis question set
respondents with an e-system in place said they have included an outreach component, and no specific
cost estimates were provided. It is possible that the need for outreach would become greater if the esystem were to completely replace, rather than supplement, the existing paper-based HM shipping paper.
7.4.3.2
Evidence from the Pilot Test Simulations
The pilot tests participants (23% roadway inspectors, 67% maritime inspectors, 60% emergency response
organizations) also commented on the need for training on any e-system used to communication the HM
shipping papers information (refer to Sections 7.2.2.5 and 7.2.3.5, respectively). In addition, 33% of
maritime inspectors and 80% of the emergency response organizations who participated in the pilot tests
reported that additional equipment is needed to implement e-HM communication (refer to Sections
7.2.2.6 and 7.2.3.6, respectively).
7.4.3.3
Evidence from Public-Private Partnership
As described in Section 3.2.3, PHMSA met with DOE’s ORNL, Turnkey, and UCOR at the Oak Ridge
Reservation in Tennessee in January 2012 to learn about RITIS, a TRL 5 e-system Turnkey developed, in
partnership with DOE, for tracking HM transported on the Oak Ridge Reservation.
Turnkey inputs data into RITIS for UCOR. Approximately 1.5 full-time equivalent (FTE)/year in labor
are required to maintain RITIS. As of January 2012, approximately $1 million had been spent on RITIS
(hardware, labor); $300,000 of this cost was associated with initial one-time setup fees. Annual operation
and maintenance costs (including labor) are approximately $250,000.
In a test of RFITS’s efficiency, Turnkey staff found that, for each truck transporting HW, the RFITS
reduced eight pieces of paper information to zero. As reported in October 2011, more than 25 DOE Oak
Ridge projects totaling almost 55,000 e-shipments have shipped via the RITIS Program, with a
corresponding cost savings of more than $16 million.92
92
Source: Nuclear Decommissioning Report, October 2011, Issue 6, Volume 1; “RFITS Takes Shipping to the Next Level.”
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7.4.4
Benefits and Costs by Mode of Transportation
The business impacts, benefits, and costs of a transition from the current paper-based hazard
communication approach to an e-system are likely to vary based on the mode of transportation. Even
within particular modes, the impacts will also vary based on factors such as business type, size, and the
range of HM commodities transported. Benefit and cost impacts may vary significantly by transportation
mode and by business type, based on considerations such as:
Whether an e-system is already being used;
Whether HM information can be accessed via or added to the e-system’s data fields; and
If the business can sustain profitability while, and/or identify a dual-benefit for, implementing an
e-system.
Findings93 from the pilot tests, stakeholder consultations, and impact analysis question sets together
provide the following general information on the nature of these differences:
93
Differences across modes exist regarding modal baselines with respect to their existing use of esystems and the nature of their HM operations. Rail, maritime, and air carriers already make use
of the EDI data format with all required HM information. While each company is different,
stakeholders in these modes generally described their readiness to use EDI as a substitute for
hardcopy shipping papers. By contrast, EDI is used to some extent in the Roadway Mode but it
has not become a widespread standard. Conversion to an e-HM approach will likely be less costly
for shippers and carriers that are already using an EDI system and will provide more immediate
business benefits in terms of reduced administrative costs. The motor carrier industry is also
distinct in having many small operators for whom the fixed costs of a technology upgrade may be
more difficult to absorb, even if subsequent benefits or savings exist.
Another consideration is that hardcopy shipping papers are used in some modes and industries for
purposes other than HM communication. Roadway Mode impact analysis question set
respondents were much more likely than others to say that HM shipping papers serve other
business functions, such as delivery confirmation, pay records, or trip logs. This response is
consistent with the information that motor carrier stakeholder groups shared with PHMSA (refer
to Section 3.3.2.3) about how shipping papers are used in their industry. These firms may thus
face additional transition costs in a move to an e-system, because they might need to make other
adjustments to their business processes to take on the roles currently performed by hardcopy
shipping papers.
Among respondents who already had experience with an e-system, those in the Roadway Mode
were more likely to state that they faced impediments, notably “problems with electronic/wireless
devices” and “problems with the communication mechanism (e.g. email, Internet)”. This response
is also consistent with information received in stakeholder communication (refer to Section
3.3.2.3) that trucking companies face issues with “dead spots” in wireless communication, and
from the roadway inspection simulations, where one issue that was noted was lack of electronic
access in rural areas. Companies facing these challenges, which appear to be concentrated in the
These findings should be viewed as preliminary due to the small and non-random samples associated with these activities.
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Roadway Mode, would thus likely face additional technological costs and complexities in
transitioning to an e-system.
Although these differences are important, there are many commonalities that exist across modes, as
shown in responses to the impact analysis question set. For example, when asked to identify the benefits
of the e-system, “increased operational efficiency” and “reduced staff time and/or cost to prepare shipping
papers” were the most common answers overall and for each modal sub-group (i.e., Air, Maritime, Rail,
and Roadway). Responses across modes were also fairly consistent in terms of the desired characteristics
of an e-system and the potential for time savings in preparing e-shipping papers versus hardcopies.
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8. Conclusions
8.1 Modal Shippers and Carriers Use of E-systems for
Communicating HM Shipping Paper Information
Many shippers in all modes already have e-systems containing HM shipping information, and should be
able to easily transition to providing shipping paper information electronically to carriers who will
transport the HM. In addition, Air, Maritime, and Rail Mode carriers generally have e-systems in place
for communicating HM shipping paper information. As long as they are allowed to use performancebased e-systems that provide them with flexibility for running their businesses in a cost-effective and
efficient manner, these shippers and carriers should be able to effectively use e-systems for
communicating HM shipping paper information.
As described in Section 7.1.2, transport of HM by roadway carriers is significantly different from their
modal counterparts for a variety of reasons. The feasibility and effectiveness of communicating HM
shipping paper information via e-systems may be difficult for some roadway carriers (e.g., those who
require a hardcopy HM paper documentation trail; cannot afford to purchase an e-system or do not see a
business reason to invest in one; do not have onboard technology for receiving and transmitting e-HM
information; transport HM in areas with Internet connectivity issues; etc.).
Shippers and carriers looking to utilize e-systems for sending and receiving e-HM data need to ensure that
accurate and complete e-HM data can be accessed 24 hours per day, seven days per week and shared in a
timely manner, and that permission protocols for authorizing shipper and carrier personnel to provide eHM information to inspectors and emergency responders are developed and implemented.
Carriers in all modes utilizing e-systems will need to visually identify HM transportation conveyances so
inspectors and emergency responders can recognize conveyances transporting HM using e-HM shipping
papers and know how to obtain the e-HM data.
Carriers who want to participate in e-HM data sharing need to ensure their operators are provided with
devices capable of receiving, storing, and transmitting e-HM information. These devices should be
removable from the transportation conveyance, for quick access and sharing of HM information with
inspectors and emergency responders. It is especially important that operators are provided with a device
that is capable of providing e-HM data directly to inspectors and emergency responders when HM is
being transported within areas of known Internet connectivity issues.
An electronic means for HM carriers to send/receive e-HM shipping documents to/from carriers in the
other modes needs to be considered during the evolution of e-systems. Also, provisions for shippers and
carriers to communicate the e-HM information in an open, easily transferrable and readable e-data format
to each other and to inspectors and emergency responders should be considered, based on the positive
pilot test results reported in Section 7.2.4.
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8.2 Law Enforcement Inspectors Use of E-systems for
Communicating HM Shipping Paper Information
As described in Sections 3.3.3.1 and 3.3.3.3, Air and Rail Mode operations personnel are required to
visually examine HM prior to transport. While both modes require the HM shipping paper information be
provided electronically, operations personnel are required to compare the hardcopy HM shipping paper
information with the physical HM prior to transport. In addition, Air Mode inspectors conduct aftershipment inspections at shipper facilities and at airport carrier locations, where they view HM shipping
papers and NOPICs required to be maintained by aircraft operators in hardcopy or via electronic image at
or through its principal place of business. As the HM shipping paper information is currently required to
be provided electronically, inspectors in these modes should be able to effectively use e-systems if
policies are adopted allowing for the use of electronic devices by these inspectors for receiving and
reviewing the e-HM information. Many inspectors in these modes already possess electronic devices
capable of receiving e-HM data; however, because many of the devices are not standardized within
LEIOs, standardized devices may need to be procured for some inspectors.
HM inspectors in the Maritime Mode (USCG container inspectors) may not be equipped with electronic
devices either capable of or permitted to be used for receiving e-HM shipping paper information during
the conduct of HM container inspections. In 2014, the USCG’s CG-FAC purchased tablets for field units
to use in conducting facility safety and security operations (refer to Section 3.1.2). While the current use
of the tablets is to make reference materials accessible to inspectors while conducting field activities, the
CG-FAC recommends that the use of such devices be expanded in the future. These devices could
potentially be used by maritime container inspectors to access e-HM shipping paper information during
container inspections. In addition, some inspectors at large ports currently receive electronic HM shipping
papers directly from the shippers, while inspectors at small and medium ports typically receive hardcopy
HM shipping papers from terminal/yard offices; such offices may receive the original HM shipping
papers electronically from either the shipper or the carrier (refer to Section 3.3.3.2). While most maritime
HM inspectors are currently not using e-systems for accessing the HM shipping paper information while
conducting container inspections, use of e-systems for HM container inspections should increase as more
ports begin expanding the use of tablets as an inspector tool. Maritime inspection organizations that invest
in technology for e-HM communications should ensure that port Wi-Fi connectivity is updated to allow
for the technology to work in the best manner possible.
As described in Section 3.3.3.4, HM inspectors in the Roadway Mode are provided with laptops, and have
access to a variety of databases for searching and storing HM information; such inspectors should be able
to effectively receive e-HM shipping paper information from shippers and carriers who have e-systems
with the capability for transmitting this information.
Policies at the Federal or state levels allowing for the purchase and use of electronic devices for
conducting HM inspections in the Air, Maritime, and Rail Modes need to be researched and evaluated to
determine whether 1) investment in such technologies will benefit the respective inspector
agencies/organizations; and 2) the technologies will make inspectors’ job responsibilities easier, faster,
and/or more efficient while providing for a work environment that is at least as safe and secure as that
provided by the current hardcopy HM shipping paper requirement. These determinations should include a
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review of the size and display capabilities of the electronic devices purchased for HM inspectors to share
and access electronic HM information, to ensure the e-HM information can be easily read within a timely
manner. HM inspectors will benefit from training on the use of electronic devices; the process that should
be followed for requesting, receiving, and relaying the e-HM data; and the potential benefits and
limitations of using e-systems for reviewing HM shipping paper information during HM inspections.
8.3 Emergency Responders Use of E-systems for Communicating
HM Shipping Paper Information
Generally, emergency responders in urban areas with existing response systems and networks should be
capable of effectively receiving and transmitting HM shipping paper information via e-systems. Some
EROs that are volunteer-based; exist in rural areas with limited Internet connectivity; reside in
geographically-challenged areas and/or areas where seasonal/weather conditions result in Internet
connectivity issues; or are not provided with electronic devices will not be able to obtain e-HM data at the
scene of an incident directly from the carrier or shipper until solutions to these issues are identified and
implemented. EROs currently possess back-up systems for obtaining HM information when shipping
papers are not available or accessible; EROs currently incapable of receiving and transmitting HM
shipping paper information via e-systems will need to rely on verbal communication of HM data from
shippers and carriers to on-scene emergency responders by means of these other layered and redundant
backup systems.
Efforts to assist EROs in investing in and understanding the benefits and limitations of using e-systems
for HM communications should be continued. Emergency responders will benefit from training on how to
use electronic devices for receiving and transmitting e-HM information. In addition, because PSAP
personnel training and professional experiences regarding HM vary greatly, providing PSAP personnel
with training on the look and content of HM shipping papers and on HM placarding symbols should be
considered.
8.4 Safety and Security Impacts of Using E-systems
Scenarios involving serious incidents with impaired hazard communication appear to be very rare in
comparison to the volume of HM shipments, but they have occurred in transportation scenarios where
HM information was lacking (such as undeclared HM shipments); was damaged or destroyed (such as fire
incidents); and was incomplete, incorrect, and/or required additional steps (such as multiple phone calls)
to provide emergency responders with all needed HM information. While e-communication would not
eliminate these scenarios, it could reduce their likelihood and/or impact.
The e-system concept requires at least an equivalent level of safety and security as compared to the
current hardcopy-based system of hazard communication. While current real-world data on the
performance of e-systems is insufficient to be able to characterize e-systems’ performance or quantify
their safety and security benefits, the following pieces of evidence provide some insight into e-systems’
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potential safety and security impacts:
Some e-systems may be able to provide improved safety by increasing the accuracy and
timeliness of information received by first responders (refer to data in Table 28 and Table 30,
which show that 19% of inspectors and 80% of emergency responders, respectively, who
participated in pilot test simulations noted positive impacts on inspection and emergency response
times).
Because HM information is maintained electronically, e-systems can reduce the possibility of
HM shipping documents being lost or damaged. In addition, software interfaces can help reduce
misspellings of chemical names and other potential sources of error.
E-systems that have redundancy capabilities are potentially more robust than hardcopy shipping
papers in the event of an incident (such as a fire that destroys hardcopy shipping papers).
In the case of a serious vehicle crash or fire, the ability to obtain HM information electronically—
and without having to approach the vehicle—may improve safety for responders and improve the
effectiveness of their efforts.
E-systems that have been verified and tested as being protected from unauthorized access may
provide better security of HM information, by requiring vetted users to provide user
authentication information prior to gaining access to HM information.
Additional safety and security impact considerations regarding the use of e-systems include impacts
associated with outages or telecommunications problems; impacts if e-system is hacked, and associated
HM data is compromised/altered/deleted; and e-system limitations (such as occasional system outages or
telecommunications problems). In addition, authorized users will need to be identified, notified, vetted,
and trained on the e-system, and access to some e-systems, especially those that involve multiple
stakeholder types, will need security access measures to allow access only to authorized users.
While the benefits associated with these safety and security impacts may improve incident response and
reduce the direct costs incurred by HM shippers and carriers in preparing and maintaining HM shipping
paper information, the full magnitude of all these impacts is difficult to quantify until more operational
experience is gained with e-systems.
8.5 Cost-benefits and Impacts of Using E-systems
The administrative and business process cost benefits and impacts of e-systems include both electronic
hazard communication and e-commerce. The benefits and impacts specific to electronic hazard
communication need to be analyzed separately from the wider range of benefits and impacts that might
accrue from e-commerce. Little information on the specific business impacts of electronic hazard
communication is known; however, evidence94 provides some insights into potential cost benefits and
impacts associated with electronic hazard communication.
94
Evidence is from the Hazardous Materials Cooperative Research Program, Report 8, Impact Analysis question set responses, and pilot test
simulations. Refer to Sections 7.2 and 7.4 for more information.
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While the degree of cost benefits is likely to vary based on the mode of transportation, the cost-benefits of
electronic hazard communication for shippers and carriers across modes are expected to be more common
in administrative areas (e.g., shipping paper preparation, tracking, filing, maintenance, retrieval, and
storage) than in operational areas (e.g., vehicle utilization, driver/operator labor costs, and fuel use).
Administrative cost savings could be produced by reducing or eliminating the need for multiple data entry
of the same HM information (e.g., shipments that use multiple modes or carriers), which in turn could
reduce data entry errors and associated data entry delays. While actual cost savings would vary,
potentially significantly, across different organizations, industries, and e-system formats, the reduction in
time required to prepare shipping papers electronically is generally expected to be more pronounced for
shippers than for carriers, and for larger firms than for small firms. Impact analysis question set data(refer
to Section 6.2) suggests a rough average of five minutes saved per shipping paper produced; in very rough
terms, a five-minute savings per shipping paper is the equivalent of approximately $1.80 in labor cost
savings per shipment, based on Bureau of Labor Statistics data.95 At the economy-wide level, the
existence of 800,00096 to 1.2 million97 daily HM shipments in the U.S. would mean that the cost saving
benefits could be substantial. Cost savings could also be significant for companies that are able to
decrease HM transit times, which could lead to broader supply chain benefits (e.g., lower inventory
costs).
Transitioning from the current paper-based system to an e-system may entail substantial implementation
costs, and is likely to vary among transportation modes. Even within particular modes, the impacts will
vary based on factors such as business type and size; the range of HM commodities transported; whether
an e-system is already being used; whether HM information can be accessed via or added to the esystem’s data fields; and if the business can sustain profitability while, and/or identify a dual-benefit for,
implementing an e-system. Development, implementation, operation, and maintenance costs could
include technology hardware and software costs, licensing, and upgrades, personnel e-system initial and
refresher training costs, and costs associated with customer outreach and education needs; these costs will
vary widely depending on the number employees requiring training and the complexity of the e-system.
Differences in transition costs are expected across modes due to differences with respect to their existing
use of e-systems and the nature of their HM operations. Rail, maritime, and air carriers already make use
of the EDI data format with all required HM information. While each company is different, stakeholders
in these modes are generally ready to use EDI for e-HM communication as a substitute for hardcopy
shipping papers. By contrast, EDI use in the Roadway Mode has not become a widespread standard, and
the motor carrier industry also has many small operators for whom the fixed costs of a technology
upgrade may be difficult to absorb, even if subsequent benefits or savings exist. Conversion to an e-HM
approach will likely be less costly for shippers and carriers that are already using an EDI system and will
provide more immediate business benefits in terms of reduced administrative costs.
95
Based on BLS Occupational Employment Statistics, May 2015.
Estimate from Hazardous Materials Shipments, USDOT/RSPA, 1998
(http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/hmship.pdf).
97
Estimate was provided via conversation with CHEMTREC staff in 2012 and was based on 2011 HM shipments.
96
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Another benefit and cost consideration is that hardcopy shipping papers are used in some modes and
industries for purposes other than HM communication. For example, the Roadway Mode uses HM
shipping papers to serve other business functions (e.g., delivery confirmation, pay records, trip logs).
These companies may face additional transition costs, because they might need to make other adjustments
to their business processes to take on the roles currently performed by hardcopy shipping papers. The
Roadway Mode is also more likely to face other implementation impediments, notably problems with
electronic/wireless devices, problems with the e-communication mechanism used (e.g. email, Internet),
and the existence of “dead spots” in wireless communication. Companies facing these challenges will
likely face additional technological costs and complexities in transitioning to an e-system.
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9. Recommendations
Based on a review and evaluation of stakeholder feedback information and pilot test and impact analysis
results, Volpe believes that e-systems can be a feasible and effective alternative to hardcopy
documentation for communicating HM shipping paper information during the transport of HM, and can
provide an equivalent level of safety and security as provided by hardcopy shipping papers, if certain
performance-based standards are met.
9.1 Recommendations for Incorporating E-systems into the
Federal HM Transportation Safety Program
Based on the findings and information collected in this study, Volpe recommends that rulemaking be
considered to amend the HMR to permit the use of e-systems for communicating e-HM shipping paper
information if a set of performance-based standards are met. Recommended performance criteria to be
evaluated and defined during the rulemaking process include requiring:
An identified POC is available for providing the e-HM information 24 hours per day, seven days
per week;
All HM shipping paper information is provided electronically on-demand within a defined time
interval after the initial request (Note: DOT-SP 15747 in Appendix H: UPS Special Permit 15747
requires that the e-HM shipping paper information be provided “without delay” to emergency
responders and inspectors in a single transmission within five minutes from when the initial
request is received by the UPS call center);
Shippers and carriers develop, document, and train (initial and refresher) affected staff on their
equipment, procedures, and security protocols associated with providing e-HM communications
in HM transportation;
A performance definition for paperless hazard communication that is flexible; permits the use of
different technologies (due to the variations in existing systems, across industry, modes, and
continually-evolving technologies); and provides the e-HM information in an open, easily
transferrable and readable e-data format is developed;
A standardized defined visual aid (such as a placard) indicating that the HM shipping paper
information will be communicated electronically, along with a means to obtain the e-HM
information (such as a POC telephone number or website) is visible on the exterior of the
transportation conveyance; and
In areas with known Internet connectivity issues, transportation conveyance operators must have
the means to directly provide the e-HM information to local HM inspectors and emergency
responders (e.g., print the HM shipping paper information directly from a device in the
transportation conveyance, show the HM shipping paper information on a laptop/tablet screen,
etc.), and are provided with a backup procedure for obtaining the HM shipping paper information
and providing the HM shipping paper information to local HM inspectors and responders.
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9.2 Recommendations for Additional E-HM Pilot Tests and
Research Studies
Any regulatory change allowing for the use of e-systems to communicate HM shipping paper information
needs to define the amount of time the shipper/carrier is allowed to provide the e-HM shipping paper
information. Section 9.1 recommends the establishment of a “reasonable time interval” for HM inspectors
and emergency responders to receive the HM shipping paper information electronically after the initial
request. If additional pilot tests are conducted, reasonable time intervals (e.g., within five minutes, as
prescribed in DOT-SP 15747) can be tested to determine if the e-HM information can be successfully
communicated to HM inspectors and emergency responders within acceptable timeframes.
Considerations also need to be made for allowing the use of e-systems to communicate e-HM shipping
paper information in rural areas, inclement weather conditions, and terrain features (such as mountains
and valleys) that may present challenges with Internet connectivity, and which can delay or prevent the
timely transmittal of e-HM data. Additional pilot tests are recommended to gain further information
regarding these potential barriers to e-HM communications.
Based on the findings and information collected under this study, Volpe recommends additional pilot tests
to examine the feasibility and effectiveness of the e-system performance-based standards recommended in
Section 9.1. The additional tests should expand on the pilot tests already conducted, involve all modes,
and utilize a larger diverse set of participants with an extended test period. These tests should include, but
not necessarily be limited to:
Tests (including backup procedures) in rural and geographically-challenged (e.g., low valleys,
high mountains, etc.) areas where Internet connectivity challenges may exist;
Tests (including backup procedures) in areas with known seasonal inclement weather conditions
(e.g., heavy rains, blizzards, etc.) where Internet connectivity challenges may exist;
Tests involving intermodal transfers;
Tests using an expanded variety of tablets and other electronic devices to transmit and receive eHM information to inspectors and emergency responders while they conduct HM inspections and
emergency response activities;
Tests involving international HM shipments; and
Studies involving the integrity and accuracy of HM shipping paper information during the
transfer of data between e-systems using different data exchange languages.
9.3 Other Recommendations Related to Use of E-systems
Based on the findings and information collected in this study, the following additional
recommendations related to the use of e-systems to communicate e-HM shipping information were
identified:
LEIOs looking to use e-systems should ensure their HM inspectors are provided with electronic
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devices capable of accessing the e-HM information in a timely manner and in a state that is easily
transferrable and readable (such as in, but not limited to, pdf format). Inspectors should receive
training on the use of their electronic devices; the process that should be followed for requesting,
receiving, and relaying the e-HM data; and the potential benefits and limitations of using esystems for reviewing HM shipping paper information during HM inspections.
EROs looking to use e-systems should ensure their emergency responders are provided with
electronic devices capable of receiving, reading, and transmitting e-HM information. Emergency
responders should be equipped with layered and redundant capabilities to provide an alternate
means for obtaining the HM information during situations where Internet connectivity and/or
power capabilities are compromised. Emergency responders should receive training on how to
use their electronic devices to receive and transmit e-HM information. PSAP personnel should
receive training on the look and content of hardcopy and e-HM shipping papers and on HM
placarding symbol meanings.
DOT, EPA, and other agencies should continue to coordinate efforts for developing and
implementing e-communications, including EPA’s E-Manifest Program.
9.4 Other Shipping Paper Considerations Recommended for
Future Study
In the process of conducting discussions with HM stakeholders, Volpe obtained additional feedback
related to the presentation and types of information the HMR currently requires to be listed on HM
shipping papers. Stakeholders, especially those from the emergency response community, stressed the
importance of needed changes to these requirements to improve the accessibility of HM information.
Although outside the scope of this study, sufficient and consistent feedback was provided such that Volpe
recommends a separate study be considered to develop and evaluate the benefits and impacts of creating a
standard, uniform format for providing the 49 CFR 172.202 required HM descriptive information on a
shipping paper. A standard format would prescribe a specific field for each descriptive element required
under the HMR (e.g., Field 1 contains the HM identification number as shown in Column 4 of the 49
CFR 172.101 Hazardous Materials Table; Field 2 displays the HM’s proper shipping name; etc.). This
standard format could potentially make e-HM transfers between different data exchange languages and
electronic data formats work smoother. During this effort, considerations could also be made for
potentially inserting additional hazard communication fields recommended by emergency responders and
HM inspectors (refer to Appendix C: Information Collected Outside Scope of Report but Related to
Project) into a standardized HM shipping paper format. Depending on the determined benefits and
impacts, this standard, uniform format could be applicable solely to e-HM shipping papers or to both
hardcopy (paper) and e-HM shipping papers. Any resulting standard format could also potentially be
added as a component to a pilot test in Section 9.2.
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10. References
Hazardous Materials Regulations, 49 Code of Federal Regulations, Parts 171 (General Information,
Regulations, and Definitions), 172 (Hazardous Materials Table, Special Provisions, Hazardous Materials
Communications, Emergency Response Information, training Requirements, and Security Plans), 173
(Shippers—General Requirements for Shipments and Packagings), 174 (Carriage by Rail), 175 (Carriage
by Aircraft), 176 (Carriage by Vessel), 177 (Carriage by Public Highway), 178 (Specifications for
Packagings), 179 (Specifications for Tank Cars), and 180 (Continuing Qualification and Maintenance of
Packagings).
Federal Register Document 02-17566, Department of Transportation, Research and Special Programs
Administration, Hazardous Materials: Retention of Shipping Papers, Docket No. RSPA-01-10568 (HM207B), RIN 2137-AC64, Federal Register Vol. 67, No. 134, filed July 11, 2002 (67 FR 46123)
(http://www.phmsa.dot.gov/pv_obj_cache/pv_obj_id_3AD2ECC155ED45E2E8C6DD53668C91C6A2C5
0000/filename/67fr-66571.pdf).
Federal Register Document 02-27735, Department of Transportation, Research and Special Programs
Administration, Hazardous Materials: Retention of Shipping Papers, Docket No. RSPA-01-10568 (HM207B), RIN 2137-AC64, Federal Register Vol. 67, No. 212, filed October 31, 2002 (67 FR 66571)
(http://www.phmsa.dot.gov/pv_obj_cache/pv_obj_id_3AD2ECC155ED45E2E8C6DD53668C91C6A2C5
0000/filename/67fr-66571.pdf).
Public Law 112-141, Division C—Transportation Safety and Surface Transportation Policy, Title III—
Hazardous Materials Transportation Safety Improvement Act of 2012, Section 33005, Paperless Hazard
Communications Pilot Program of the “Moving Ahead for Progress in the 21st Century Act, 112th
Congress, H.R. 4348, signed into law on July 6, 2012 (http://www.gpo.gov/fdsys/pkg/BILLS112hr4348enr/pdf/BILLS-112hr4348enr.pdf).
Transportation Research Board, Hazardous Materials Cooperative Research Program, Report 4, Project
HM-04: Emerging Technologies Applicable to Hazardous Materials Transportation Safety and Security,
2011 (http://onlinepubs.trb.org/onlinepubs/hmcrp/hmcrp_rpt_004.pdf).
Transportation Research Board, Hazardous Materials Cooperative Research Program, Report 8, Project
HM-05: Evaluation of the Use of Electronic Shipping Papers for Hazardous Materials Shipments, 2012
(http://onlinepubs.trb.org/onlinepubs/hmcrp/hmcrp_rpt_008.pdf).
International Civil Aviation Organization. “Technical Instructions for the Safe Transport of Dangerous
Goods by Air.” Last modified May 26, 2015. Accessed July 2015.
http://www.icao.int/safety/dangerousgoods/pages/technical-instructions.aspx.
International Air Transport Association. “Dangerous Good Regulations.” Last modified January 1, 2015.
Accessed July 2015. http://www.iata.org/whatwedo/cargo/dgr/.
USCG Memorandum 13480, IPad Use in the Field, from A.E. Tucci, CAPT COMDT, (CG-FAC) to
LANT-54, PAC-54, June 30, 2014.
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Association of American Railroads, “U.S. Hazardous Materials Instructions for Rail.” January 4, 2011.
http://boe.aar.com/boe/download/US_HMI.pdf.
Federal Register Document 20863, Department of Transportation, Pipeline and Hazardous Materials
Safety Administration, Hazardous Materials: Incorporating Rail Special Permits into the Hazardous
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| File Type | application/pdf |
| File Title | Blank Technical Report Template |
| Author | Laurie Butts;Laura Waldon |
| File Modified | 2017-04-20 |
| File Created | 2016-12-01 |