PHMSA Issues Q&A Regarding The Use Of Electronic Shipping Papers
The U.S. DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued a guidance document on methods for transferring product transfer documents (shipping papers) while adhering to social distancing requirements.
The guidance is important to petroleum marketers and heating fuel dealers because it clarifies that while electronic shipping papers for hazardous materials may be used for all parties along the distribution chain, including for shippers certification signatures, hard copies of shipping papers must still be kept in the cab of the cargo tank transport truck at all times in the event of an accident or investigation.
This guidance does not apply to heating fuel delivery tickets left with commercial and residential customers.
State law requires delivery tickets to be left with customers at the time the tank is filled and not electronically transferred – unless, otherwise waived by a State for COVID-19 social distancing purposes.
Currently, PMAA is not aware of any such state waiver.