Do Dangerous Goods Belong on Driverless Vehicles?

Do Dangerous Goods Belong on Driverless Vehicles?

In late March 2018, US DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) released a request for information related to the development of automated technologies for transporting hazardous materials by surface modes, i.e., highway and rail.

By requesting input from industry hazmat shippers, carriers, and supply-chain professionals, PHMSA is taking the first step toward developing regulations to be applied to driverless vehicles carrying hazmat.

See the RFI here, published with corrections by PHMSA on March 29. 

Renew your hazmat shipper certification and take away 49 CFR compliance resources designed to simplify compliance. The DOT Hazmat Ground Shipper Certification Workshop comes to Los Angeles, Las Vegas, Sacramento, Denver, Kansas City, and Minneapolis in April—and doesn’t stop there.  Check out the full DOT hazmat training schedule.

Will “Driverless” trucks really be driver-less?
Based on the current state of autonomous vehicles, we presume that while an employee may not “drive” the truck, a “safety engineer,” “operator,” or “attendant” will be in the vehicle during transport. Having a trained hazmat employee in the truck will be critical—at least until the next leap in artificial intelligence.

Hazmat package inspection and acceptance check
Drivers carry out a crucial function for hazardous materials carriers; they inspect hazmat packages and determine whether the consignment complies with 49 CFR, then accept or reject the shipment accordingly.

Without a trained hazmat employee representing the carrier during cargo acceptance, will shippers be loading hazmat using the honor system? Speaking of loading hazardous materials…

Loading and unloading hazardous materials
Often, drivers take on the hazmat pre-transportation job function of loading dangerous goods onto the truck. The driver may need to segregate materials that are incompatible or block, brace, or secure the load to prevent shifting in transit. 

Further, when loading cargo tanks, the person loading the tank (often a driver) must attend to the cargo tank to ensure everything goes as planned [49 CFR 172.177(h)(i)].

Without a driver to perform these functions, shippers will need to expand their hazmat training programs to include 49 CFR training for loading and unloading materials.

Preserving and providing emergency response information
When a hazmat transportation incident occurs, the driver is always the first responder on site. During an incident or release, drivers must grab the emergency response information that first responders will need and get free from danger.

How will local response teams get the emergency response information they need, if not from the driver? Will DOT set up an electronic system, similar to the upcoming EPA Hazardous Waste Manifest? Local governments will need to collect and store a lot of data to provide accurate, timely response info to responders without a driver or attendant in the vehicle.

En-route security and driver attendance requirements

For high-hazard materials, bulk chemical shipments, and other materials covered under 49 CFR 172 Subpart I, US DOT requires measures to address en-route security, including security during storage incidental to movement.

The requirements for high-explosives (Divisions 1.1, 1.2, 1.3) are even more explicit. These rules—found at 49 CFR 397.5—require a truck carrying such explosives on a public street or highway always be attended, with a few exceptions.

Collisions or incidents during hazmat transport
When a truck—whether carrying hazmat or not—collides with another vehicle, blows a tire, jack-knifes, or is otherwise disabled in transit, the driver is often responsible for warning motorists of the hazard by laying out flares, reflective flags, etc. Someone must be responsible for warning motorists in these situations, especially if the cargo is hazardous material and poses threats beyond traffic problems.

The comment period for this RFI is open until May 7, 2018. How to submit your comments.

How Can Hazmat Shippers Prepare?
As auto manufacturers start rolling out autonomous vehicles for the trucking industry, shippers face challenges that go beyond the usual insurance and liability issues.

To ensure that workers can take on new or unfamiliar hazmat jobs traditionally performed by drivers, hazmat shippers and carriers will need to bolster hazmat training programs to cover new functions like loading or unloading materials.

Lion Technology offers hazmat training for managers and employees at any experience level. From the comprehensive DOT Hazmat Ground Shipper Certification Workshop and online course to recurrent DOT hazmat training options and courses that cover specific hazmat jobs—like the Hazmat Loading Dock Worker and the Shipping Hazmat by Ground—Ops online courses.

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