November 29, 2021

Volume XI, Number 333

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November 29, 2021

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DOT Issues Guidance on Hazmat Shipping Papers and Social Distancing

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.

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

© 2021 Keller and Heckman LLPNational Law Review, Volume X, Number 104
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About this Author

Trent Doyle Environmental Compliance Attorney Keller Heckman Law Firm
Partner

Trent M. Doyle advises clients on all types of environmental matters, including compliance with U.S. and international chemical control laws, transportation of dangerous goods regulations, hazardous materials regulations, and community right-to-know laws. He also has special expertise in environmental permitting.

Mr. Doyle counsels clients on a wide spectrum of environmental and transportation matters, including those pertaining to chemical control, facility permitting (e.g., Clean Air Act, Clean Water Act), hazardous materials shipping...

202-434-4161
Taylor D. Johnson ASSOCIATE Keller Heckman California's Proposition 65 Chemical Control Environmental Litigation Transportation Workplace Safety and Health
Associate

Taylor Johnson is an environmental lawyer specializing in the area of environmental regulation of products, including chemical control, pesticides, energy efficiency regulation, and importantly, domestic and international transportation of hazardous materials. Mr. Johnson also advises clients on community-right-to-know laws, Proposition 65, occupational safety and health matters, and supports a wide variety of commercial tort and other litigation issues.

Mr. Johnson has special expertise in the area of hazardous materials transport, including enforcement defense and compliance...

202-434-4255
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