Comment from Explore Information Services, Inc.

Docket PHMSA-2022-0043 Comments We wish to comment on the use of electronic means of communicating certain hazard communication related information in lieu of paper. We would like to offer our perspective on the use of a mobile application that replaces the Emergency Response Guidebook (“ERG”). Our comments pertain narrowly to Part 172, Subpart G Emergency Response Information. More specifically, the comments are intended to reflect the perspective of the hazardous material endorsed commercial truck driver who may infrequently haul placarded quantities of hazardous material, but who may not have expertise or considerable practical experience dealing with the unintentional spill or release of hazardous materials. We are an information and technology company who have developed an application for use by commercial truck drivers to assist in safely handling and transporting hazardous materials. Our product, Hazmat Informer, is intended to help drivers of varying degrees of experience easily and effectively interpret applicable hazardous material transportation rules; properly placard loads containing hazardous materials; and safely transport those materials. Hazmat Informer users merely enter certain information from the shipping papers into the application including: the UN or NA number(s) of any hazardous materials indicated on the shipping papers, their packaging, and weight and depending upon those entries, certain additional information may be asked. Our application then applies the regulations and first determines the proper segregation of materials if applicable and then recommends the proper placard(s) to use for the load. Once placarding is verified and completed, the commercial driver then completes an automated briefing that reminds the drivers of the applicable rules and safety practices associated with transporting those specific materials. Our application includes an electronic ERG solution that links directly to those UN/NA numbers indicated to be present within a given load. Such that if an emergency arises, the user simply clicks the ERG button and is taken directly to the appropriate ERG link. The application takes the guesswork out of the process for the user and greatly reduces the time spent matching the UN number to the correct Guide number. Any novice user of the ERG can sympathize with the frustration and delay of thumbing through a book looking for the right page. Our solution greatly reduces confusion and speeds up response. Some might argue concerns with accessing electronic information. Some might point out that formatting might vary and make it more challenging for emergency responders to read or interpret what is provided electronically. Some might argue that if there is a fire, that the information might be lost. We would offer up the following points to address such concerns: 1.We agree that if electronic communication is used, the information should be available to emergency responders. There are a couple ways to do this. First, require that the information for a subject load be stored locally on the device and backed up on a server. Two, permit by rule EITHER paper or electronic Emergency Response Guidebooks. Thus, a Commercial driver subject to 172 Subpart G may use an electronic version (formatted similarly to the existing paperback book). And, a 3rd party emergency responder, if they so choose, can use their paperback book. So long as both are pointing the same UN number and Guide number, the rule should be satisfied. 2.The Formatting for an electronic version of the ERG should be similar to the paper version. However, there are innate advantageous to the type of application for example we have designed. Namely, the user does not have to know the guide number or search through a book to match the guide number to the UN number(s) of the subject load. This is a time-consuming task and novice users are very apt to error in their use of the paper guidebook. 3.Yes, a fire or some other catastrophic event could destroy the hardware on board making an electronic version of the ERG inaccessible. However, such an event is just as likely to make the paper version of the ERG inaccessible. We would argue, in the case of Hazmat Informer, that an electronic version of the application (typically downloaded on a smart phone) is much more likely to survive such an event. Most users will have the device on their person. In the event of a fire or some other scenario where the driver evacuates the cab suddenly, they are very likely to have or keep the device on them. We believe the existing rules are too rigid and stifle the kinds of innovation possible that make electronic solutions superior to their paper counterparts in many cases. We believe PHMSA can simplify compliance by allowing the use of an electronic Emergency Response Guidebook and that such a change in the regulation will have a positive impact on safety. Explore Information Services