Deadline: April 13, 2026
Hazardous Materials: Harmonization With International Standards
49 CFR Parts 171, 172, 173, 175, 176, 178, and 180
IHMM has begun its review of the PHMSA NPRM on HM-215R. Below is an outline of where we are as of today. We seek certificant input into what will become IHMM comments filed with PHMSA on or before April 13, 2026.
I. Statutory and Regulatory Purpose
A. Statutory Authority
The proposed rule is issued pursuant to the Hazardous Materials Transportation Act (HMTA), 49 U.S.C. §5120, which directs the Secretary of Transportation to ensure that U.S. hazardous materials transportation regulations remain generally consistent with international standards unless doing so would reduce safety or conflict with national interests.
B. Core Objectives
The NPRM seeks to:
Maintain alignment between the U.S. Hazardous Materials Regulations (HMR) and international dangerous goods regulations.
Facilitate international trade and multimodal transportation.
Reduce compliance costs by eliminating regulatory discrepancies.
Maintain or enhance transportation safety.
C. Regulatory Framework
The rule proposes amendments across multiple HMR parts governing:
Hazardous materials classification
Packaging requirements
Hazard communication
Air transport limits
Vessel stowage provisions
These amendments incorporate updates from international regulatory bodies and codes.
II. International Standards Being Harmonized
PHMSA proposes adoption or incorporation of updates from:
A. United Nations Model Regulations (23rd Revised Edition)
B. ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air
C. International Maritime Dangerous Goods (IMDG) Code
D. ADR – European Agreement Concerning the International Carriage of Dangerous Goods by Road (2025 edition)
E. UN Manual of Tests and Criteria (Rev. 8)
F. Globally Harmonized System of Classification and Labelling of Chemicals (GHS Rev. 10)
Purpose of harmonization:
Standardize classification systems
Align shipping names and hazard classes
Ensure consistent packaging and labeling globally
III. Major Regulatory Amendments Proposed
A. Changes to the Hazardous Materials Table (HMT)
The rule proposes revisions to §172.101 to:
Add new proper shipping names (PSNs)
Revise hazard classes
Update packing groups
Modify special provisions
Revise packaging authorizations
Adjust air transport quantity limitations.
B. Sodium-Ion Battery Regulations
The NPRM introduces new transport provisions for sodium-ion batteries consistent with UN Model Regulations and ICAO standards.
Key elements:
• Creation of new HMT entries
• Definition of “sodium ion cell or battery”
• Alignment with lithium battery regulatory framework.
Regulatory purpose
Anticipate growing commercial use of sodium-ion battery technology and ensure early regulatory coverage.
C. Lithium and Sodium Battery Air Transport Restrictions
The proposal expands state-of-charge limits for certain batteries transported by air.
Purpose:
Reduce fire risks
Align with ICAO air transport safety standards.
D. Limited Quantity Expansion for Compressed Gases
The rule proposes to authorize limited quantity shipments (≤1000 ml) for certain Division 2.2 gases:
Argon (UN1006)
Carbon dioxide (UN1013)
Helium (UN1046)
Nitrogen (UN1066)
This expansion applies for modes other than air transport.
Purpose:
Reduce packaging burden for low-risk shipments.
E. Organic Peroxide Transport Authorizations
The rule proposes:
Adding three peroxide formulations to §173.225.
Authorizing additional packaging for certain formulations.
Purpose:
Allow transport without individual PHMSA approvals when safety conditions are satisfied.
F. Reclassification of Tetramethylammonium Hydroxide (TMAH)
The NPRM proposes:
New HMT entry for aqueous TMAH solutions
Revised hazard classification reflecting toxicity hazards
Updated special provisions and packaging requirements.
Purpose:
Reflect new toxicity data and international regulatory changes.
G. Fire Suppressant Dispersing Devices
Two new entries proposed:
UN0514
UN3559
These devices would require PHMSA explosives approval prior to transport.
H. Terminology and Definitions
Section 171.8 would add definitions for:
Sodium-ion batteries
Purpose:
Clarify regulatory scope and applicability.
IV. Incorporation by Reference Updates
The rule updates incorporated standards such as:
GHS Rev. 10
ADR 2025
UN Manual of Tests and Criteria Rev. 8
These updates affect hazard communication and classification systems.
V. Economic and Policy Considerations
A. Cost Reduction
Harmonization reduces compliance costs for:
multinational shippers
manufacturers
freight forwarders
B. International Trade
Aligning with global standards eliminates regulatory barriers to export shipments.
C. Safety Neutrality
PHMSA states the rule will maintain current levels of safety while improving consistency.
VI. Impact on Professional Practice
A. CHMM (Certified Hazardous Materials Manager)
Key effects:
Regulatory compliance oversight
Updated classifications and shipping names
Battery transport regulations
Chemical hazard reclassification.
Hazard communication
Alignment with GHS Rev. 10 labeling systems.
Facility shipping programs
Updating shipping documentation and SDS-related transport classifications.
Corporate compliance programs
Revising transportation policies and internal procedures.
B. CHMP (Certified Hazardous Materials Practitioner)
Operational impacts:
Updating shipping procedures
Revising packaging selection
Managing limited-quantity shipments
Implementing new battery transport restrictions.
Practitioners will likely handle day-to-day implementation of the new HMR provisions.
C. CDGP (Certified Dangerous Goods Professional)
The rule has significant implications for CDGP professionals due to international harmonization.
Key areas:
Multimodal shipping alignment
ICAO / IMDG / ADR consistency.
Battery shipping compliance
Lithium and sodium battery air transport.
Dangerous goods classification
New entries and hazard reclassifications.
Packaging approvals
Organic peroxide and explosive device approvals.
VII. Strategic Compliance Implications
Organizations shipping hazardous materials will likely need to:
Update dangerous goods training programs
Revise shipping manuals and SOPs
Update electronic shipping systems
Modify SDS transportation sections
Conduct internal regulatory gap assessments.
VIII. Likely Areas of Industry Comment
Stakeholder comments are expected on:
Battery transport restrictions
TMAH toxicity classification
Limited quantity gas expansions
Administrative burden of new approvals
Implementation timelines.
✅ Bottom Line
HM-215R is primarily a harmonization rulemaking intended to align the U.S. Hazardous Materials Regulations with evolving international dangerous goods standards. While many amendments are technical, they will materially affect classification, packaging, and transport requirements—particularly for battery technologies, specialty chemicals, and multimodal shipping operations.
| Topic | CHMM | CHMP | CDGP |
|---|---|---|---|
| Overall compliance significance | High. CHMMs overseeing enterprise hazardous materials compliance will need to revise transportation governance, classifications, and internal controls. | High. CHMPs handling practical implementation will likely manage day-to-day procedural changes. | Very High. CDGPs are most directly affected because this rule is centered on dangerous goods harmonization across modes and international codes. |
| Hazardous Materials Table revisions | High. Corporate programs, audits, and management systems will need updated shipping descriptions, hazard classes, packing groups, and special provisions. | High. Shipping staff instructions, package selection, and documentation workflows will need revision. | Very High. Core dangerous goods classification work changes directly with new and revised HMT entries. |
| Sodium-ion battery regulation | Moderate to High. Relevant where organizations manufacture, import, store, or ship emerging battery systems. | High. Procedures for packaging, marks, training, and acceptance will need updating. | Very High. New sodium-ion entries and rules mirror lithium battery transport and will be central to DG practice. |
| Lithium/sodium battery air transport state-of-charge rules | High for organizations with air shipments or battery-powered products. | High. Packing and pre-shipment verification processes will change. | Very High. Air-mode acceptance and compliance review will become more technical and more consequential. |
| Tetramethylammonium hydroxide (TMAH) reclassification | High. CHMMs responsible for chemical hazard governance and transport classification will need to reassess affected inventories and SDS transport sections. | High. Operational controls, labeling, packaging selection, and shipping papers will need revision. | High. CDGPs will need to apply the new toxic/corrosive framework and associated special provisions accurately. |
| Fire suppressant dispersing devices | Moderate. More relevant to manufacturers, importers, and specialized users. | Moderate to High where these devices are handled in operations. | High. New entries and approval-linked transport conditions will be important for DG specialists. |
| Limited quantity relief for certain Division 2.2 gases | Moderate. May reduce regulatory burden and shipping costs in some product lines. | High. CHMPs may implement simpler packaging and shipping workflows for eligible shipments. | High. CDGPs will need to determine eligibility and mode limits, especially because the relief excludes air transport. |
| Organic peroxide table amendments | Moderate. Important where chemical manufacturing or specialty formulation is involved. | Moderate to High. Could reduce the need for prior approvals in some cases. | High. Packaging and classification authorization details are core DG functions. |
| International harmonization value | High. CHMMs benefit from reduced friction in multinational compliance systems and supply chains. | High. Easier operational alignment across domestic and export shipments. | Very High. Harmonization with ICAO, IMDG, ADR, and UN standards is central to CDGP work. |
| Training implications | High. Management-level compliance training, internal policy revisions, and audit criteria must be updated. | Very High. Front-line shipper and packer training will need prompt revision. | Very High. Recurrent DG training content will need substantive updating across air, vessel, and multimodal practice. |
| Documentation/SOP revisions | High. Enterprise SOPs, shipping manuals, and compliance matrices will need revision. | Very High. Work instructions, package prep sheets, and acceptance checklists will change. | Very High. Shipping descriptions, special provisions, and mode-specific checks will require detailed revision. |
| Strategic business effect | High. CHMMs may use the rule to reduce compliance friction and improve export readiness. | Moderate to High. Operational efficiency may improve if procedures are updated well. | High. CDGPs may see expanded demand for classification, training, auditing, and international shipping support. |
CHMM:
This NPRM matters most at the program management and governance level. A CHMM will likely be responsible for aligning company policy, training, hazard classification governance, and multimodal compliance systems with the revised HMR. The largest CHMM impacts are battery regulation, chemical reclassification, and enterprise procedure updates.
CHMP:
This NPRM matters most at the implementation level. CHMPs will likely be the professionals who translate the final rule into shipping instructions, packaging decisions, shipping paper changes, and employee training updates. The practical effect is immediate and operational.
CDGP:
This NPRM is likely the most directly significant for CDGPs. Because the proposal centers on harmonization with international dangerous goods systems, the CDGP role sits at the heart of the changes. Battery transport, modal restrictions, stowage, packaging, special provisions, and international description alignment are all core CDGP competencies.
Plain-English conclusion
If finalized substantially as proposed, HM-215R would affect all three credentials, but not equally.
The CDGP is likely the most directly impacted, the CHMP the most operationally burdened, and the CHMM the most strategically responsible for program-level adaptation.
