Self-Driving Trucks with Hazmat? DOT Proposes Safety Updates Now
Published Date: 12/4/2025
Proposed Rule
Summary
The Department of Transportation wants to update rules to make it easier and safer to transport hazardous materials using self-driving vehicles. This affects companies moving dangerous goods and invites everyone to share their thoughts by March 4, 2026. These changes aim to keep things safe while embracing new technology, with no immediate costs announced yet.
Analyzed Economic Effects
10 provisions identified: 0 benefits, 5 costs, 5 mixed.
Highway Hazmat Transport Could Be Restricted
PHMSA and FMCSA note that Automated Driving Systems (ADS) raise unique issues and that FMCSA previously requested comment on whether transporting hazardous materials in fully automated commercial motor vehicles should be restricted or prohibited; PHMSA is seeking input on how ADS could affect hazardous materials rules on highways.
Possible Changes to Special Permits
PHMSA says any person can currently request relief from the Hazardous Materials Regulations via the Special Permit process, and as of November 2025 it had received two applications seeking relief for highly automated systems delivering consumer products by unmanned aircraft. PHMSA is asking whether changes to the special permit process are needed to handle highly automated transportation systems and specifically requests comment on whether proposed revisions would impose high costs or disproportionately burden small businesses.
Shipping Papers Could Go Digital
PHMSA notes that shipping papers and emergency response information must accompany most hazardous materials shipments and that highly automated systems may not have a person onboard to hand over physical documents. PHMSA is seeking comment on using electronic shipping papers and automated incident notification systems to provide cargo, location, and emergency information.
Marking, Labeling, Placarding May Be Revised
PHMSA says hazard communication (markings, labels, and placards) is critical but may be hard to apply for last-mile deliveries or UAS operations where packages may be outside an airframe or visible from different angles. PHMSA is asking for input on alternatives and notes that the International Association of Fire Fighters recommended table 1 and table 2 materials should never be authorized for highly automated systems when placards would be required.
Training Requirements May Be Reassessed
PHMSA notes that Part 172 training requirements apply to hazardous materials employees and that highly automated systems may change job roles, reduce human interaction, or replace trained hazmat employees. PHMSA seeks input on whether training should be revised or replaced with safety assurance and certification systems for automated operations.
Security Plans and Cyber Risks May Change
PHMSA notes that security plan requirements (Part 172 subpart I) apply to materials that present significant security threats and that highly automated systems could raise unique security and cybersecurity concerns. PHMSA is seeking input on whether security plan applicability and in-depth security training should be revised for these systems.
Packaging Standards May Be Updated
PHMSA says packaging requirements in Parts 173 and 178 may need new designs or performance standards to work with different automated platforms and to address risks specific to those platforms. PHMSA seeks input on packaging changes for highly automated transportation systems.
Air UAS/AAM Operators Face HMR and FAA Rules
PHMSA explains that UAS and Advanced Air Mobility (AAM) operators that carry hazardous materials must meet HMR requirements and obtain FAA approvals such as an OpSpec A055 and part 135 or proposed part 108 certifications, including accepted hazardous materials manuals, approved training programs, and Safety Management Systems. PHMSA is seeking input on how air-specific HMR provisions apply to automated air operations.
Loading/Unloading Rules May Be Adapted
PHMSA notes that some HMR requirements, like Sec. 175.90(a) which requires inspection after delivery by air, may be impractical for unmanned deliveries to private homes. PHMSA is asking how loading and unloading procedures in the HMR should change for highly automated deliveries.
Rail Hard-Copy Consist Requirement Under Review
PHMSA highlights that Sec. 174.26 requires railroads to provide train consist information in hard-copy form prior to movement and notes this could conflict with highly automated rail operations that do not have a train crew. PHMSA is reviewing whether HMR changes are needed to accommodate crewless or highly automated rail movements.
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