In July, the Pipeline and Hazardous Materials Safety Administration issued an Advanced Notice of Proposed Rulemaking seeking comments on a possible proposal to allow motor carriers to maintain electronic copies of hazardous materials shipping documents. It’s an effort to acknowledge the technical capabilities of the 21st century and leverage digital documentation to drive efficiency and eliminate errors. Sadly, HM shipping papers are one of the last bastions of required paper documentation as most federal agencies, with a few exceptions (we’re looking at you, ODAPC) have already adopted rules, as required by Congress, to convert from paper to electronic. Now, after years of research and demonstration projects, PHMSA has finally posed the question to its stakeholders: if we decide to allow electronic HM shipping documents, how should we do it?
Sadly, as of this writing, only 10 comments have been submitted, eight of which opposed the change. Most of the opposition were emergency responders who highlighted dusty old claims about crashes in locations without cellular coverage or the trials of attempting to view a document on a screen on a sunny day. To these luddites, paper is king and its throne shall not be usurped. Like others who came before them, the mantra is “if it ain’t broke, why fix it.” STC is not here to argue the system is broken, we’ll leave that for another day, however, we will point out that this mindset stands in the way of progress. When Gutenberg invented the printing press, pens and pencils worked just fine and had for generations. But his drive for progress and innovation unlocked literacy worldwide. Imagine if the book transcribing industry had prevailed because people worried they couldn’t read the typeface.
Too often, new ideas (if you can call electronic documents new), are met with apprehension. Some who are unsure how innovation will change their lives are quick to point out potential problems and set up roadblocks to implementation to scuttle the entire project. At STC, we like to look for ways to get to YES! It is 2022 after all. This requires seeing past the way things are done today and thinking outside the constructs of how emergency responders have been trained to respond to crises. After all, vehicles are learning to drive themselves, which may make exchanging paper shipping documents difficult in the future anyhow. It may be time to get ahead of the curve.