In workshops sponsored by the Pipeline and Hazardous Materials Safety Administration (PHMSA), emergency responders and law enforcement personnel have voiced concerns about the possibility of shippers and carriers of hazardous materials (HMs) being given the option to use electronic shipping papers in place of hard copies. 

One major reservation is that too much information would be transmitted electronically at the site of an accident or investigation.  Other concerns include ensuring that the e-shipping paper received is the correct one; this link between the shipper and the shipping paper is almost never in question with a hard copy since the paper is in the vehicle.

HMTSIA

The workshops are part of an effort to implement HM-ACCESS, a provision of the Hazardous Materials Transportation Safety Improvement Act of 2012 (HMTSIA).  HM-ACCESS authorizes PHMSA to run a number of pilot projects in partnership with other modal administrations, law enforcement, emergency response organizations, and industry representatives to evaluate the feasibility of allowing the use of e-shipping papers for HM shipments. 

The overall goal of HM-ACCESS is to improve the availability and speed by which information is available to emergency responders; improve the security of imported containers through better knowledge of shipments and reduced potential for diversion; and allow U.S. companies to compete more effectively in the global economy by using the best tools available.  The current United Nations Model regulations contain recommendations for the use of e-shipping papers to improve global harmonization.

Instantaneous and accurate

But participants in the workshop identified multiple “concerns, gaps, and vulnerabilities” with both the option of requiring either e-shipping papers or hard copies or a mandatory transition to e-papers.  For example:

• Too much information can be detrimental (i.e., information other than what is required under 49 CFR Subpart C may result in response delay).
• The information must be available instantaneously and must always be accurate.
• The volume of data could become unmanageable, leading to capacity limitations such as bandwidth and storage.
• Equipment and data are not standardized.
• Backup systems are needed.
• New devices must be acquired to receive e-HM information.
• Inaccurate and missing information in the paper-based system could be carried over to an e-system.
• Rural, remote, and geographically challenging areas may have no or limited e-communication.
• Some small/volunteer departments have limited Internet connectivity or no wireless capability.

48-hour wait

On the other hand, the switch toward electronic-based shipping papers appears inevitable, PHMSA notes.  Other federal agencies (the EPA, DOD, and DOE) have implemented or are planning to implement e-HM communication programs.  Also, according to law enforcement personnel at the workshop, 75 percent of motor carrier inspections are now completed electronically.  An e-system in the future that provides shipping paper information instantaneously and in one record during an inspection (e.g., on a tablet provided by the driver) would be acceptable to most inspectors, PHMSA found. 

The U.S. Coast Guard agreed that an e-system would shorten the time needed to access papers during port inspections, which can now take  up to 48 hours at some ports.

PHMSA adds that it is well aware of obstructions to e-communication in some rural areas, citing as an example an area a few miles outside of Denver, Colorado, that has very limited Internet access because of its geography.  The HMTSIA also addresses these concerns to some extent and requires that at least one of the pilot projects conducted under HM-ACCESS take place in a rural area.

HM-ACCESS pilot tests are scheduled to begin during the second half of 2013 and be completed in 2014.

Click here for summaries of PHMSA’s workshops.