IHMM is proud to announce that it has formally submitted comprehensive comments to the Pipeline and Hazardous Materials Safety Administration (PHMSA) in response to its Notice of Proposed Rulemaking (HM–215R), a sweeping regulatory update governing the transportation of hazardous materials and dangerous goods across all modes.

This rulemaking is not routine—it is foundational. PHMSA’s proposal implements critical updates to the Hazardous Materials Regulations (HMR), aligning U.S. requirements with international standards such as the UN Model Regulations, ICAO Technical Instructions, IMDG Code, and ADR. These changes directly affect how hazardous materials are classified, packaged, labeled, and transported in a global economy handling more than 3.3 billion tons of hazardous materials annually.

Why This Matters

At its core, this rule is about safety, compliance, and global interoperability. It introduces significant updates, including:

  • Revisions to the Hazardous Materials Table (HMT)
  • New regulatory frameworks for emerging risks such as sodium-ion batteries
  • Expanded air transport requirements for battery state-of-charge
  • Chemical reclassifications (e.g., TMAH toxicity updates)
  • Expanded harmonization with international dangerous goods systems

These are not academic changes—they will reshape day-to-day compliance decisions, training requirements, and enforcement exposure across industries.

IHMM’s Objective: Elevating the Role of Certified Professionals

IHMM’s comments go beyond technical recommendations. We have made a clear, strategic case to the federal government:

Certified hazardous materials professionals must be formally recognized as a critical component of regulatory compliance and public safety.

Consistent with federal policy under OMB Circular A-119 and the National Technology Transfer and Advancement Act, IHMM urged PHMSA to:

  • Recognize CHMM®, CHMP®, and CDGP® certificants as qualified professionals in regulatory guidance and preambles
  • Encourage the use of certified personnel in classification, packaging, and compliance decisions
  • Incorporate competency-based expectations into training and enforcement frameworks

This is about ensuring that who performs the work is as important as what the rules require.

What This Means for You

For CHMMs (Certified Hazardous Materials Managers):
This rule will significantly impact enterprise-level compliance systems. CHMMs will need to update governance frameworks, audit protocols, SOPs, and cross-functional compliance strategies. The rule also strengthens the case for CHMMs as the strategic leaders of regulatory integration and risk management.

For CHMPs (Certified Hazardous Materials Practitioners):
CHMPs will be on the front lines of implementation. From revising shipping procedures to updating packaging, labeling, and documentation workflows, this rule will drive immediate operational changes. Training requirements will expand, and procedural accuracy will be more critical than ever.

For CDGPs (Certified Dangerous Goods Professionals):
This rule is directly centered on your domain. With expanded harmonization across international codes and new classifications (especially batteries and emerging technologies), CDGPs will experience the most significant technical impact. Demand for your expertise in classification, multimodal compliance, and training will increase substantially.

The Bigger Picture

IHMM’s filing is about more than one rulemaking. It is about:

  • Raising the visibility of IHMM and its ANSI-accredited credentials
  • Positioning certificants as indispensable to regulatory success
  • Ensuring government recognition of professional competency as a best practice

We have made it clear: safe transportation of hazardous materials depends not just on regulations—but on qualified, credentialed professionals implementing them.

What Comes Next

IHMM will continue to engage with PHMSA throughout the rulemaking process and stands ready to:

  • Support implementation through training and education
  • Provide technical expertise and stakeholder engagement
  • Advocate for the formal recognition of certified professionals in federal regulatory frameworks

This is your profession. This is your moment.

As these regulations evolve, IHMM certificants are not just affected—they are essential to making them work.