Hazmat security plans: PHMSA moves to renew the paperwork, and the notice spells out who needs a plan
Comments on OMB control number 2137-0612 are due Jan. 11, 2027. Here is which shipments trigger a written security plan and how much time PHMSA says the plans take.
The Pipeline and Hazardous Materials Safety Administration (PHMSA) plans to ask the Office of Management and Budget to renew the information collection behind hazardous materials security plans, and it is taking public comment until Jan. 11, 2027. The notice was filed Nov. 10 and is set for publication in the Federal Register on Nov. 12.
It covers two OMB control numbers. PHMSA will request a three-year approval for each.
Who needs a written security plan
Part 172 of the Hazardous Materials Regulations requires people who offer or transport certain hazardous materials to develop and put in place written plans to improve the security of those shipments. The plan requirements in 49 CFR 172.800(b) apply to specific types of shipments. According to the notice, these include, but are not limited to:
- Shipments of more than 3,000 kg (6,614 pounds) of solids or 3,000 liters (792 gallons) of certain liquids and gases in a single packaging, such as a cargo tank motor vehicle, portable tank, tank car or other bulk container
- Any quantity of a Division 1.1, 1.2 or 1.3 material
- A large bulk quantity of a Division 2.1 material
- Any quantity of a poison-by-inhalation material
PHMSA says a security plan helps shippers and carriers reduce the chance that a hazmat shipment is used as a weapon of opportunity by a terrorist or criminal.
Because the list in the notice is not complete, check the full 172.800(b) list against your own freight before deciding a plan does not apply to you.
What PHMSA estimates the plans cost in time
The notice breaks out the burden for OMB control number 2137-0612. For companies writing or updating plans, PHMSA estimates:
- New plan, large companies: 30 respondents, 90 responses a year, 50 hours each
- New plan, small companies: 170 respondents, 170 responses a year, 25 hours each
- Updating a plan, large companies: 6,300 respondents, 18,900 responses a year, 10 hours each
- Updating a plan, small companies: 35,700 respondents, 35,700 responses a year, 5 hours each
The same control number also covers rail-only tasks, such as commodity data and route analysis for Class I, II and III railroads. Across everything in 2137-0612, PHMSA counts 43,128 respondents, 55,974 annual responses and 425,854 burden hours a year.
The second collection
The notice also covers OMB control number 2137-0640, a generic clearance for voluntary, low-burden feedback surveys on how PHMSA delivers its services. PHMSA estimates 6,000 respondents and 3,000 burden hours a year.
How to comment
Comments must include docket number PHMSA-2026-3961 (Notice No. 2026-05). You can file them through the federal eRulemaking portal at regulations.gov, or by mail or hand delivery to the DOT Docket Management System at 1200 New Jersey Avenue SE, Washington, DC 20590. Comments are posted publicly without change, including any personal information.
For a copy of the information collection, the notice lists Ryan Larson or Steven Andrews of PHMSA's Standards and Rulemaking Division, (202) 366-8553.