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DOT Issues Guidance on Hazmat Shipping Papers and Social Distancing

Date: Apr 13, 2020

On April 10, 2020, the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Notice to address inquiries regarding the shipping paper requirements specified in the DOT Hazardous Materials Regulations (HMR) in light of social distancing to address COVID-19. [1]

In the Notice PHMSA emphasizes that, under the HMR, no physical contact between parties is necessary in order to meet requirements applicable to shipping papers (49 CFR 172 Subpart C). PHMSA provides examples of how shipping papers may be signed and shared while maintaining social distancing (e.g., using e-mail, requesting another person to sign on shipper’s behalf, etc.). Although not addressed in the Notice, it bears noting that individuals who sign shipping papers for hazardous materials shipments are subject to the full DOT HMR training requirements specified in 49 CFR Part 172, Subpart H.

For any questions on this Notice or the shipment of hazardous materials in general, please contact us.

Trent Doyle (+1 202.434.4161), doyle@khlaw.com

Taylor Johnson (+1 202.434.4255), johnsont@khlaw.com

[1] https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2020-04/PHMSA%20Shipping%20Paper%20Notice.pdf