We have a PHMSA ANPR [linked below] that merits your attention and response before Friday, the 13th of February, to give us time to assemble comments on or before the deadline of March 4, 2026.

Federal Register – Deadline March 4, 2026

Synopsis of the Proposed Rulemaking

The linked document above is an Advance Notice of Proposed Rulemaking (ANPRM) issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) seeking stakeholder input on whether and how the Hazardous Materials Regulations (HMR; 49 CFR Parts 171–180) should be revised to accommodate the transportation of hazardous materials using highly automated transportation systems.

The ANPRM does not propose regulatory text. Instead, it initiates a comprehensive policy inquiry addressing the growing use of automated and semi-automated systems—including unmanned aircraft systems (UAS/drones), automated commercial motor vehicles, autonomous rail operations, and maritime autonomous surface ships—to move hazardous materials in commerce.

PHMSA’s stated purpose is to determine whether existing HMR provisions—largely designed around human-operated transportation models—remain adequate, or whether revisions, guidance, definitions, or performance-based alternatives are needed to ensure equivalent or enhanced safety in automated environments.

The ANPRM identifies seven core regulatory areas potentially affected:

  1. Special permits
  2. Shipping papers and emergency response information
  3. Hazard communication (marking, labeling, placarding)
  4. Training
  5. Security plans and in-depth security training
  6. Packaging
  7. Loading and unloading

PHMSA also conducts a mode-by-mode analysis (rail, air, vessel, highway) and poses extensive technical, economic, and legal questions to inform a future Notice of Proposed Rulemaking (NPRM). Public comments are due March 4, 2026.

Implications for IHMM Credential Holders

CHMMs (Certified Hazardous Materials Managers)

For CHMMs, this ANPRM signals a paradigm shift in hazmat compliance management. Core compliance functions—shipping papers, hazard communication, employee training, incident reporting, and security planning—may transition from human-centric processes to system-centric, performance-based models.

CHMMs will be increasingly expected to:

  • Interpret HMR applicability where no driver, pilot, or crew is present
  • Oversee electronic shipping paper systems and automated emergency notification protocols
  • Integrate automation risk assessments into compliance programs
  • Manage cross-agency requirements involving PHMSA, FAA, FMCSA, FRA, TSA, and USCG

This rulemaking elevates the CHMM role from traditional compliance oversight to governance of automated safety systems.

CHMPs (Certified Hazardous Materials Practitioners)

CHMPs will be directly affected at the operational and implementation level. The ANPRM foreshadows changes to:

  • Packaging performance standards for drone and automated vehicle transport
  • Inspection, acceptance, and rejection processes conducted remotely or autonomously
  • Modified training models where “hazmat employees” may be system monitors rather than handlers
  • New security and cybersecurity considerations tied to automated platforms

Practitioners will need to translate evolving regulatory intent into standard operating procedures that remain defensible under enforcement scrutiny.

CDGPs (Certified Dangerous Goods Professionals)

For CDGPs operating in international or multimodal contexts, the ANPRM raises important harmonization and divergence risks. PHMSA explicitly solicits comment on alignment with:

  • ICAO Technical Instructions
  • IMDG Code
  • UN Model Regulations
  • Emerging IMO MASS frameworks

CDGPs will need to navigate potential mismatches between U.S. HMR automation rules and international dangerous goods regimes, particularly for air and maritime transport involving unmanned or highly automated systems.

Bottom Line for IHMM

This ANPRM represents an early but consequential step toward rewriting the regulatory assumptions underlying hazardous materials transportation. If finalized, future rules will materially expand the professional scope, technical expectations, and legal exposure of CHMMs, CHMPs, and CDGPs.

IHMM and its certificants are well-positioned—and arguably essential—to inform PHMSA’s approach, particularly on:

  • Training equivalency
  • Performance-based compliance models
  • Small-entity impacts
  • Practical enforceability in automated operations

Strategic engagement at the ANPRM stage can shape the regulatory framework that will define hazardous materials management for the next decade.