If PHMSA Inspected Your Company Today: Would You Pass?

Published February 03, 2026

On November 20, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) released a memo that shifts how it prioritizes inspections and enforcement actions. For companies that manufacture, ship, package, or transport hazardous materials in the United States, this memo provides valuable insight into PHMSA’s current inspection and enforcement focus, making it an important resource for inspection readiness.

What Changed in PHMSA's Enforcement Approach?

The memo from the Office of Hazardous Materials Safety (OHMS) emphasizes targeting inspections and enforcement where they provide the greatest positive impact on hazardous materials safety, while avoiding overly broad or novel interpretations of regulations.

In practice, this means PHMSA inspections will be increasingly risk-based rather than purely random. The memo identifies specific inspection priorities, outreach initiatives, and enforcement standards that regulated entities should understand and prepare for immediately.

PHMSA's Strategic Priorities: What Companies Should Know

PHMSA is focusing on three key areas: outreach, inspections, and enforcement standards.

Outreach Priorities

PHMSA emphasizes proactive engagement to improve compliance before enforcement becomes necessary. This includes strengthening communication with hazmat shippers, clarifying packaging selection requirements, and promoting accurate classification of materials prior to shipment. Because packaging and classification remain among the most common sources of violations, staying informed is critical.

Companies that actively participate in PHMSA webinars, seek regulatory guidance, and implement good-faith compliance practices are generally less likely to have errors or non-compliance issues. By staying informed and applying best practices, these companies reduce the risk of violations before an inspection ever occurs.

Inspection Priorities

PHMSA’s inspections now focus on operations that present the highest safety risk or recurring compliance concerns. Priority targets include:

General hazardous materials shippers and offerors
Cylinder requalification and manufacturing facilities
Drum manufacturing and recertification operations
Lithium battery shippers
E-commerce platform shippers with potential undeclared hazardous materials

PHMSA also emphasizes follow-up inspections for companies with prior violations to verify that corrective actions were implemented. Inspections are increasingly data-driven and risk-based, rather than routine or evenly distributed.

Enforcement Standards

PHMSA’s enforcement approach is now timely, consistent, and risk-focused. Violations posing the greatest risk to public safety, the environment, or transportation security receive enforcement priority. By leveraging trend analysis and case management data, PHMSA identifies recurring violations and emerging risks, meaning companies with compliance gaps or a history of violations should expect increased scrutiny.

What PHMSA Will Likely Request During an Inspection

While the memo doesn’t list specific records, PHMSA inspections routinely review documentation that demonstrates compliance. Based on standard practices, inspectors may request:

For Hazmat Shippers and Offerors:

Hazmat Employee Training (49 CFR 172.704)

Initial and recurrent training (every 3 years) covering: general awareness, function-specific tasks, safety, and security awareness
Training records must be maintained while employees perform hazmat functions and for 90 days afterward
Documentation of training completion and testing/certification

Shipping Papers and Documentation (49 CFR 172.200–205)

Proper shipping name, hazard class, identification number (UN/NA)
Packing group and total quantity
Emergency response information (49 CFR 172.602), including a 24-hour emergency contact number
Retention: 1 year minimum (3 years for hazardous waste shipments)

Packaging Selection and Certification (49 CFR 173)

Evidence that packaging was selected according to the Hazardous Materials Table (49 CFR 172.101)
Packaging specifications and certification documents
Requalification records for reusable containers (cylinders, IBCs, etc.)
Proof that packaging meets performance standards for materials shipped

Security Plans (49 CFR 172.800–804, if required)

Written security plan for companies shipping high-consequence materials
Security awareness training documentation
Personnel security background checks (if applicable)

Incident Reports (49 CFR 171.15–16)

Immediate notice of certain hazmat incidents
Written incident reports filed with PHMSA (Form F 5800.1)
Internal incident investigations and corrective actions

Attention: Failure to provide requested documentation promptly—typically within minutes—can itself indicate inadequate safety management controls. Missing multiple documentation categories may be seen as a systemic deficiency.

Conducting Your Compliance Self-Assessment

Don’t wait for PHMSA to discover gaps. Here’s how to evaluate readiness:

Immediate Assessment (This Week)

Emergency Response Information: Test your 24-hour emergency contact and make sure your provider has your most up-to-date information, including the correct contact person, current Safety Data Sheets (SDS), and relevant shipping details.
Training Status: Identify hazmat employees whose training expires within 90 days, verify records are accessible and complete, and confirm that training covers all four required areas.
Recent Shipments Audit: Review the last 10 shipments to ensure shipping papers are complete, packaging selection matches Hazardous Materials Table requirements, and emergency contacts are correct.

Comprehensive Assessment (This Month)

Create a master list of all hazmat employees with training dates and expiration tracking
Review your training program to ensure it meets 49 CFR 172.704 requirements
Implement a compliance calendar for recurrent training, container requalification, and other recurring obligations
Document procedures and responsibilities for packaging selection, classification, and shipping paper preparation

Ongoing Compliance Activities

Subscribe to PHMSA regulatory updates, safety notices, and Federal Register publications
Conduct quarterly internal audits of shipments, training records, and emergency contacts
Participate in industry associations, webinars, and networking for best practice sharing
Engage professional consultants for complex compliance areas as needed

The Strategic Value of Compliance

Being compliant with hazardous materials regulations is about more than avoiding fines or enforcement actions. At its core, compliance exists to protect people, property, and the environment from the serious risks inherent in the transportation of hazardous materials.

Companies that maintain strong safety management systems, deliver thorough employee training, and keep accurate, accessible documentation are actively contributing to this mission, reducing the likelihood of accidents, spills, or other harmful incidents. Conversely, gaps in compliance or reactive approaches don’t just increase regulatory scrutiny—they increase the risk of events that can cause injury, environmental damage, and significant operational disruption.

Key Regulatory References

PHMSA Enforcement Priorities Memo (Nov 20, 2025)
Hazardous Materials Regulations: 49 CFR Parts 171–180
Hazmat Training Requirements: 49 CFR 172.704
Emergency Response Information: 49 CFR 172.602

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