PHMSA’s 30 Investigative Questions

PHMSA’s 30 Investigative Questions

In a recent Federal Register, PHMSA shared a list of “general investigative questions” they would like to ask hazardous materials shippers during an audit or safety investigation.

PHMSA is inviting comments until August 12, 2024. Stakeholders are invited to comment on whether the proposed questions are necessary for the proper performance of the agency’s functions, the accuracy of the agency’s estimate of the burden, ways to enhance the quality/clarity of the information collected, and ways to minimize the burden of said collection.

The Federal Register notice can be found at https://www.govinfo.gov/content/pkg/FR-2024-06-12/pdf/2024-12844.pdf.

There are 30 questions covering an array of topics, including Introduction questions, general hazardous materials information, hazardous materials training, safety, emergencies/incidents, industry process/SOP, carrier/shippers/testers/manufacturers, and packaging.

The questions include:

1. Introduction Questions
   a. What are your typical operations? Can you provide a general overview?
   b. To the best of your knowledge, was a hazardous material involved in your operations?
   c. If yes, please provide the proper shipping name.

    

2. General Hazardous Materials (Hazmat) Information
   a. Can you describe the hazardous materials in transportation you normally see?
       i. How often do you see them?
       ii. Are you shipping them?
       iii. Are you storing them?
   b. Are there any specific requirements for the condition of the hazardous material that must be followed before the identified material is transported?
   c. Have these conditions been verified? If so, what was the method used?
   d. Are there modal-specific (rail/air/ vessel/highway) requirements for this hazardous material that you follow? If so, what are they?
   e. Do the locations accepting your hazardous material have any concerns/ special accommodations when receiving your hazardous material?
   f. Do shipping agents (e.g., insurance companies, shippers) have specific requirements when accepting your hazardous material?
   g. Which hazard class(es) of hazardous materials in transportation do you routinely see?

    

3. Hazardous Material Training
   a. Which employees/departments are trained to be able to handle this hazardous material? Who conducts this training?
   b. When was the last time training was provided?
   c. How do you determine who needs training?

    

4. Safety
   a. What have you or your industry done to mitigate risk around this hazardous material?
   b. What solutions have been found to be helpful during hazardous materials incidents?
   c. How would you handle a hazardous material found to be damaged or not properly packaged?
   d. Are there any special requirements in place or instructions when hazardous materials are present?

    

5. Emergencies/Incidents
   a. Do you have the means to contain the hazardous material if there is an accident or an incident?
   b. What remediation companies are potentially contracted at this location or by this company?
   c. Are you familiar with security plan requirements?

    

6. Industry Process/SOPs
   a. Can you identify other companies involved in the transportation of this hazardous material? Can you share their contact information?
   b. What are the locations of your hazardous materials operations?
   c. Can you share the Standard Operation Procedures (SOP) for the handling of hazardous materials at your company?
   d. Are you familiar with registration requirements?
   e. Who signs and prepares shipping papers?
   f. Do you transport any hazardous materials in compliance with an approval or special permit?
   g. Do you have any type of validation process for hazardous material shipping?

    

7. Carriers/Shippers/Testers/ Manufacturers
   a. Do you manufacture any hazardous material packaging?
   b. Are any other entities involved with the preparation, handling, or transportation of hazardous materials?

    

8. Packaging
   a. Where do you purchase hazardous materials packaging?
   b. Is the product loaded at any specific temperature/pressure?
   c. What types of packaging do you routinely see/use for hazardous materials transportation? Including bulk, non-bulk, and/or cylinders.
   d. At what interval are you having the package tested? Who performs this function? Are there records?
   e. How are you closing the packages? Which tools or other equipment are used?

Share your thoughts with PHMSA; they encourage feedback, both positive and negative.

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