Federal Register  Deadline April 13, 2026

According to the Federal Register from February 10, 2026, PHMSA issued NPRM HM-215R to amend the U.S. Hazardous Materials Regulations (HMR; 49 C.F.R. Parts 171–180) to maintain statutory alignment with updated international dangerous goods standards, as directed by 49 U.S.C. § 5120.

IHMM requests comments back to IHMM Executive Director Eugene A. Guilford, Jr., CAE, no later than April 1, 2026

Purpose and Authority

The NPRM seeks to harmonize the HMR with the most recent editions of:

  • the ICAO Technical Instructions (2025–2026),

  • IMDG Code Amendment 42–24,

  • Transport Canada TDG Regulations (2023), and

  • the 23rd Revised UN Model Regulations.

PHMSA concludes these updates will preserve current safety levels while reducing compliance friction, shipment delays, and duplicative regulatory burdens for U.S. entities engaged in domestic and international commerce.

Principal Regulatory Changes

The proposed amendments include, among others:

  • Incorporation by Reference of the updated international standards listed above.

  • Revisions to the Hazardous Materials Table (49 C.F.R. § 172.101) affecting proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, and modal quantity limits.

  • Expanded limited-quantity allowances for certain non-flammable compressed gases (e.g., argon, nitrogen, carbon dioxide, helium) for non-air transport.

  • New and revised provisions for emerging technologies, notably lithium and sodium-ion batteries, including enhanced emergency response information for UN3536 battery-powered equipment.

  • Targeted relief and clarifications, such as exceptions for nitrocellulose membrane filters used in medical test devices and refined transport conditions for ammonium nitrate hot concentrated solutions.

Regulatory Findings

PHMSA preliminarily finds the rule not economically significant, expects net cost savings, and anticipates no significant impact on small entities. The agency also proposes a Finding of No Significant Impact (FONSI) under NEPA, subject to public comment.

Potential Impact on IHMM Credential Holders

CHMM — Certified Hazardous Materials Manager

CHMMs will see direct operational relevance. The revised Hazardous Materials Table, new battery classifications, and updated special provisions require CHMMs to reassess internal compliance programs, SOPs, and training materials. Harmonization reduces dual-system complexity but raises the bar for technical proficiency in international standards, especially for organizations shipping batteries, gases, or specialty chemicals. The rule reinforces the CHMM’s role as the principal interpreter and implementer of evolving HMR requirements.

CHMP — Certified Hazardous Materials Practitioner

For CHMPs, HM-215R materially affects day-to-day execution: shipment classification, packaging selection, documentation, marking, and emergency response information. Expanded limited-quantity allowances and clarified exceptions may reduce administrative burden, but only if correctly applied. Misclassification risk increases during transition periods, elevating the importance of CHMP expertise in frontline compliance and audits.

CDGP — Certified Dangerous Goods Professional

CDGPs are uniquely positioned beneficiaries of this rulemaking. The NPRM explicitly centers on international harmonization across air, vessel, rail, and highway modes. CDGPs advising multinational shippers, carriers, and freight forwarders will be critical in aligning U.S. HMR obligations with ICAO, IMDG, and UN requirements. Demand for CDGP-level advisory services, training, and gap analyses is likely to increase as regulated entities seek to leverage harmonization while avoiding enforcement exposure.

Bottom Line for IHMM

HM-215R strengthens—not diminishes—the professional relevance of IHMM credentials. The rule underscores the necessity of credentialed expertise to navigate increasingly technical, globally aligned hazardous materials regulations, positioning CHMMs, CHMPs, and CDGPs as indispensable compliance leaders during and after implementation.

HM-215R NPRM — Provision-to-Credential Domain Mapping

1. Incorporation by Reference of Updated International Standards

(ICAO TI 2025–2026; IMDG Code Amendment 42-24; UN Model Regs, 23rd Rev.; Transport Canada TDG 2023)

CHMM Domains Impacted

  • Regulatory Compliance & Governance
    Requires updating corporate compliance frameworks to recognize revised international authorities now incorporated into U.S. law.

  • Program Management & Oversight
    Necessitates enterprise-wide policy revisions, contract language updates, and training alignment.

CHMP Domains Impacted

  • Hazardous Materials Classification & Documentation
    Day-to-day reliance on updated PSNs, packing groups, and modal rules.

  • Operational Compliance Execution
    Increased responsibility to verify shipments against harmonized—but revised—standards.

CDGP Domains Impacted

  • International & Multimodal Dangerous Goods Transport
    Core competency. Harmonization significantly expands CDGP relevance for cross-border and multimodal shipments.

  • Advisory & Compliance Interpretation
    Heightened demand for reconciling ICAO/IMDG/UN requirements with HMR enforcement expectations.

2. Amendments to the Hazardous Materials Table (49 C.F.R. § 172.101)

(Revised PSNs, hazard classes, packing groups, special provisions, quantity limits)

CHMM

  • Risk Assessment & Regulatory Strategy
    Changes directly affect hazard communication risk, enforcement exposure, and insurance posture.

  • Training & Competency Assurance
    Requires retraining of staff responsible for classification and shipping decisions.

CHMP

  • Material Identification & Classification
    Immediate impact on classification accuracy and shipping paper preparation.

  • Packaging & Marking Compliance
    Revised authorizations and limits affect packaging selection and inspections.

CDGP

  • Global Harmonization Analysis
    Ensuring that U.S. HMT changes align with UN Dangerous Goods List entries for international consistency.

  • Client/Employer Advisory Services
    Advising when legacy classifications are no longer valid.

3. Expanded Limited Quantity Allowances for Division 2.2 Gases

(Argon, Nitrogen, Helium, Carbon Dioxide — non-air modes)

CHMM

  • Cost & Operational Efficiency Oversight
    Potential compliance cost reductions require policy updates and risk acceptance decisions.

  • Internal Controls & Audit
    Ensuring limited quantity relief is not misapplied.

CHMP

  • Shipment Preparation & Verification
    Correct application of limited quantity thresholds is execution-critical.

  • Marking & Labeling
    Avoiding mislabeling that could trigger enforcement actions.

CDGP

  • Modal & Jurisdictional Differentiation
    Advising on when relief applies domestically but not internationally or by air.

4. New Sodium-Ion Battery Transport Provisions & Lithium Battery Revisions

(Including enhanced emergency response for UN3536)

CHMM

  • Emerging Technology Risk Management
    Integration of new battery chemistries into compliance and emergency planning.

  • Incident Preparedness & Response Planning
    Board-level concern due to fire and toxicity risks.

CHMP

  • Emergency Response Information Accuracy
    New requirement to identify predominant battery chemistry is an operational obligation.

  • Packaging, Stowage & Handling
    Increased scrutiny on compliance with battery-specific requirements.

CDGP

  • Advanced Battery Transport Advisory
    One of the fastest-growing international DG risk areas.

  • Multimodal Emergency Response Coordination
    Aligning emergency information across ICAO, IMDG, and HMR regimes.

5. Revised Provisions for Tetramethylammonium Hydroxide (TMAH)

(Reclassification recognizing toxicity in addition to corrosivity)

CHMM

  • Hazard Communication & Worker Safety Policy
    Reclassification heightens liability and duty-of-care expectations.

  • Compliance Governance
    Necessitates updates to SDS management and internal chemical approval processes.

CHMP

  • Classification & Packaging Execution
    Increased risk of misclassification due to new UN numbers and hazard profiles.

  • Handling & PPE Awareness
    Operational safety implications for handlers.

CDGP

  • International Chemical Hazard Alignment
    Ensuring consistency between U.S. and UN toxicity recognition.

  • Regulatory Interpretation
    Advising multinational clients on reclassification impacts.

6. Exceptions for Nitrocellulose Membrane Filters (Medical Test Devices)

CHMM

  • Regulatory Relief Evaluation
    Determining when exceptions may be safely relied upon without increasing liability.

  • Supply Chain Risk Management
    Particularly relevant to healthcare and diagnostics sectors.

CHMP

  • Exception Qualification Verification
    Misuse of exceptions is a frequent enforcement trigger.

  • Packaging Compliance
    Strict adherence to specified packaging conditions.

CDGP

  • International Medical Supply Chain Compliance
    Advising on whether equivalent relief exists outside the U.S.

Strategic Takeaway for IHMM

HM-215R tracks directly into every IHMM credential domain, with the deepest regulatory authority impact on CHMMs, the highest execution risk for CHMPs, and the greatest market expansion opportunity for CDGPs.

From a credential-defense standpoint, this NPRM strongly supports IHMM’s position that formal certification—not informal experience—is increasingly necessary to navigate modern, harmonized hazardous materials regulation.