Evaluation of the Use of Electronic Shipping Papers for Hazardous Materials Shipments (2012)

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1 S U M M A r Y Introduction Project Objective The objective of this project was to develop a road map for the use of electronic shipping papers as an alternative to the current paper-based hazardous material communication system. The road map addresses the electronic transfer of safety, operational, regulatory compliance, and emergency response data and documentation, for and among all carrier transport modes including highway, rail, marine, and air. Problem Statement/Discussion A hazardous material shipping paper is a shipping order, bill of lading, manifest, or other shipping document serving a similar purpose and containing the information required by Part 172, Section C of the Hazardous Materials Regulations (HMR). The HMR are issued by the U.S. Department of Transportation’s (U.S. DOT’s) Pipeline and Hazardous Materials Safety Administration (PHMSA). The HMR do not require that shippers use a special form, but require that descriptive information be provided in a specific sequence. A proper hazardous materials shipping description includes a basic description (identification number, proper shipping name, hazard class, and packing group if applicable), additional information that depends on the materials and mode of transport, quantity of hazardous material(s), and type of packing used. The U.S. DOT requires that carriers have a shipping paper with the hazardous materials shipment in a specified location in the transporting vehicle for the duration of the trip, and both the shipper and carrier must retain a copy of this shipping paper for a period of time after the shipment has reached its final destination. Hard copy hazardous materials shipping papers have some drawbacks. A hazardous materials shipment may be exchanged between different modes and different vehicles within a mode, which is more easily handled electronically since the current paper documents may not be easily interchangeable. A hard copy system is labor-intensive and subject to human error. Hard copy documents are perishable to the extent that in some hazardous materials incidents the shipping papers may be destroyed, removing vital emergency response information. While there is a substantial amount of e-commerce conducted within transportation, especially if faxes are included, in other aspects of our lives electronic transactions have long since superseded the exchange of paper as a requirement. For example, e-commerce is rou- tinely used by banks, investment firms, and healthcare providers to transmit large amounts of sensitive information quickly and securely. It is very common for an individual to pay bills Evaluation of the Use of Electronic Shipping Papers for Hazardous Materials Shipments

2and file income taxes online and withdraw money from an ATM in cases where paper may serve as a record of receipt but is not required for the transaction. Why then are electronic transactions not in greater use in commerce related to transpor- tation in general, and more particularly to types of commerce in which hazardous materials electronic shipping papers could be used? How can the e-commerce systems that have the potential to enable more widespread use of electronic shipping papers better meet the diverse needs of the hazardous materials stakeholder groups? The research from HMCRP Project 05 explored these and other questions in considering issues and strategies for advancing the use of electronic shipping papers. It should be emphasized that this research evaluated the use of electronic shipping papers for hazardous materials transportation as an alternative to hard copy shipping documents rather than a replacement for them. “Alternative” was interpreted to mean that electronic ship- ping papers are a voluntary replacement for hard copy shipping papers under circumstances where hard copies are not required, and work in conjunction with hard copies where those are required, rather than as a mandatory replacement of hard copies by electronic shipping papers. This research recognizes the benefits of unifying the growing advantages of an electronic shipping paper system in a way that it becomes increasingly desirable and attainable, so that the hazardous materials transportation community is not bound by the limitations of hard copy shipping papers. While certain segments of the hazardous materials transportation community are currently using electronic shipping papers consistently and successfully, it must be recognized that a process of standardization and adoption is needed for the larger community to attain the potential benefits of a unified electronic shipping paper system. Nomenclature. The term “hazardous materials” is most commonly used in the United States; the more universal term worldwide is “dangerous goods.” Both terms are used in this document and are interchangeable. Hazardous materials are often referred to in this document by the commonly accepted, abbreviated form of “hazmat.” Similarly, electronic shipping papers are hereafter referred to as “ESP,” an abbreviation that also applies to the association of hazmat ESP with their corresponding, required emergency response infor- mation. In this document, both of these terms—hazmat and ESP—refer to both singular and plural usage for convenience, although verb agreement depends on the context. The Hazardous Material Regulations are referred to as the “HMR.” The terms “marine mode” and “ocean mode” (also referred to by some sources as “maritime mode” or “water mode”) are essentially interchangeable, although inland barge transport is not included in ocean mode. The terms “paper” and “hard copy” referring to shipping papers or bills of lading are used interchangeably. Where there is mention of hazmat classes and divisions, they are per U.S. DOT designations. While international standards and commerce are discussed, this document references stakeholder organizations that are primarily North American. Nevertheless, the research recognizes that the needs, challenges, and solutions are truly international. Definitions of terms and acronyms and abbreviations are found in Appendix A. Project Approach and Findings Focus The heart of HMCRP Project 05 was the creation of a road map that describes the benefits of, and the path toward, creating a unified ESP system that supports interoperability and exchange of standardized electronic commerce for hazmat transportation. The road map demonstrates how affected stakeholder organizations can implement an electronic hazmat documentation and data transfer system. The research also identifies a methodol- ogy for proof-of-concept exercises designed to test the implementation strategies and

3 functionality of an electronic hazmat documentation and data transfer system identified by the road map. The research initially examined the needs of those organizations involved with shipments of placarded hazmat including hazardous waste, although the research also considered ESP in the benefits of transportation-related electronic document transactions in general. It examined the needs of key stakeholder groups, including motor carriers, railroads, ocean shippers, and cargo-carrying airlines; emergency responders; regulatory agencies; and associations, organizations, and agencies affiliated with the preceding groups. The research examined current practices involving electronic transactions, including those applicable to hazmat transportation, and impediments to more widespread use of ESP. It resulted in a critical examination of how a unified ESP system could emerge. Organization HMCRP Report 8 is organized as follows: • Summary • Chapter 1: Background • Chapter 2: Research Approach [including project objectives, problem statement, and pre- liminary findings (Tasks 1 through 3)] • Chapter 3: Findings and Applications (Tasks 4 through 7) • Chapter 4: Conclusions • References • Appendix A: Acronyms, Abbreviations, and Terms • Appendix B: Initial Research Interview Summary and Guideline • Appendix C: Results of Initial Research Interviews • Appendix D: Technology That Can Benefit Stand-Off Detection of ESP by Emergency Response and Regulatory Compliance Personnel Chapter 2: Research Approach Chapter 2 describes the major tasks followed to conduct the project’s research as well as the major results and insights garnered from the tasks: • Task 1: Gather information, • Task 2: Develop sample process maps of common and complex hazmat shipments, • Task 3: Submit an interim report based on the findings of Tasks 1 and 2, • Task 4: Submit a draft road map for the implementation of a cost-effective electronic hazmat documentation and data transfer system, • Task 5: Propose a methodology for proof-of-concept exercises, • Task 6: Submit the road map and a draft final report that documents the entire research effort, and • Task 7: Respond to project panel comments and submit the final report. The methods followed for the project’s tasks and their findings are summarized in the following. Task 1: Gather Information. The research conducted under this task identified relevant information concerning the use of ESP, electronic freight management (EFM) systems, and enforcement and emergency response issues surrounding access to and use of hazmat

4shipment information. The task included a literature search and interviews with selected stakeholders. Literature sources reviewed were general publications, professional journals, websites, media reports, and other materials. In total, there were approximately 50 direct interviews conducted, in addition to surveys of specific carrier groups by their respective associations. The interviews were conducted by telephone or in person. Some individuals were provided copies of the questions in advance and were contacted to gather additional information about their responses. The interviews involved (1) 22 organizations, including government agencies, carrier and trade associations of various modes, and a council; (2) 23 carriers of all modes, and (3) four national emergency response organizations. Some additional interviews were also conducted, such as with a wireless technology provider. The discussion under Task 1 was organized as follows: 1. Current use of ESP and EFM systems in general, 2. Enforcement and emergency response issues related to hazmat shipping information, and 3. Issues involving the implementation of electronic data interchange (EDI) systems The research described three systems implementing EDI applications that could serve to contribute valuable insights into what works. The Bolero system is based on an initial entry, created by a transaction, followed by messages related to the transportation and shipment. By documenting specific messages along the entire shipping process, the Bolero system is able to track where a bill of lading and shipment are at all times. TradeNet, another EDI application, is an electronic network that facilitates international trade by integrating all the processing procedures for import, export, and trans-shipment documents and licenses. It uses a single document to fulfill all the trade documentation requirements, and that document is routed electronically to all the parties associated with trading. U.S. Customs and Border Protection (CBP) implemented the Automated Commercial Environment (ACE) (1), the commercial trade processing/truck manifest system, to facilitate legitimate trade and strengthen border security. With ACE, motor carriers and other eligible parties are required to transmit advance electronic truck cargo information to CBP through a CBP- approved EDI. [It should be noted that Canada has its counterpart to ACE, the Advance Commercial Information (ACI) system (2).] For all of the systems investigated, maintaining a high level of security was a key requirement, and all of the systems included mechanisms to accomplish this. The literature review and interviews also identified enforcement and emergency response issues. In general, emergency responders and enforcement personnel favor any mechanisms that enhance their ability to accomplish their jobs more effectively. Emergency responders believe that the presence of ESP in addition to paper provides an added option in an emergency. For example, the emergency responders indicated that in a situation where a hazmat vehicle is burning and the hard copy hazmat papers may be unavailable, obtaining the shipping papers electronically could be another way of identifying the nature of the hazmat cargo, thus enabling more rapid deployment of the most suitable response measures. Similarly, regulatory compliance enforcement personnel indicated that the presence of electronic emergency response papers could provide quicker access to information about the type and quantity of hazmat in cargo and enable their personnel to improve inspection efficiency. Important issues revolve around the specific method employed to make ESP available to emergency response and enforcement personnel. Impediments relate to such issues as how ESP data will be collected and stored and how emergency responders and enforcement

5 personnel will access these electronic papers. As expected, the potential costs of the program for a centralized system as well as costs of equipment and training for field personnel are seen to present a formidable obstacle to adoption. (It should be noted that a centralized system was not suggested as the goal or expected outcome of the research; however, some interviewees chose to offer their thoughts on a potential centralized system.) Task 2. Develop Sample Process Maps of Common and Complex Hazmat Shipments. The research conducted under this task described the transportation of hazmat across various modes. It examined process activities and relationships, which were shown at a relatively high level. Process activities and relationships are generic in nature since individual industries, carriers, shippers, or transportation intermediaries may have unique processes for their handling of hazmat shipments. Carriers across various modes treat hazmat shipments with care, starting with shipment booking. Carrier databases are used to varying degrees in managing this process. In many cases, all documentation required for hazmat transportation is generated from the carrier system based on the booking information. Documentation and electronic notification for forwarders and interlining carriers are often generated from the carrier’s system. (Interlining is a voluntary commercial agreement between individual carriers to handle cargo that requires multiple carriers.) Special equipment or loading requirements are involved in hazmat shipments. Stowage and loading plans for less-than-truckload (LTL), ocean, and air carriers are critical since these conveyances combine a multitude of shipments and commodities. Proximity and handling of hazmat commodities in mixed conveyances are of critical importance. Carriers prepare stowage plans or hazmat manifests to enable emergency responders to quickly identify commodity locations. Through the information obtained by reviewing the literature and interviewing stake- holders, an initial sample process map was developed that incorporated the specific elements that are present in most shipment types. This initial process map was ultimately used as a basis for developing distinct process maps for a number of unique shipment profiles. Process maps were developed for each mode [two for highway mode: truckload (TL) and LTL]. The TL process flow shown in Figure S-1 is straightforward and serves as a useful model for understanding the basic interrelationships between shipper (consignor), carrier, and receiver (consignee). There are only one carrier, one vehicle (typically), and three parties involved. The represented business processes between consignor and consignee are generalized. In TL shipments, the documents, including shipper’s hazmat certification, move with the shipment. Task 3. Submit an Interim Report Based on the Findings of Tasks 1 and 2. The litera- ture search and interviews and resulting process maps show that electronic communication offers many advantages over paper-based communication. For the shipper, all information pertaining to the shipment can be instantly delivered to anyone designated to receive it. For the freight forwarder or carrier, data are more reliable because they reflect the content of the shipper’s computer. In addition, ESP are more likely to be presented in a standardized format, and electronic communication is a less time-consuming method for companies to process documentation. The primary benefits to carriers are through the reduction of operational costs, primarily in back-office clerical activities. The quantification of such savings depends greatly on the level of process automation for the implementing carriers and their partners and the types of solution implemented. Finally, ESP offer the potential for emergency responders to remotely learn about the details of the cargo that are critical to protecting the health and safety of the responders and the public.

Truckload C a r r i e r C o n s i g n o r C o n s i g n e e Pre-shipment Shipment Receive PO Process Order/ Make Book Shipment Receive Booking Confirm Booking Receive Booking Confirmation Ship Order Pick up Shipment Create Purchase Order Send PO Send ASN Dispatch Truck Receive ASN In-Transit Request Delivery Appointment Receive Delivery Request Send Delivery Confirmation Receive Delivery Confirmation Deliver Shipment Receive Shipment Hazmat Classify/Package/ Mark Hazmat Prepare Certification Shipping Papers Transfer Yard Figure S-1. Truckload process map.

7 The report emphasized that for users to realize the widespread benefits from ESP, there must be both effective standardization and implementation. Implementation of a standardized shipping paper format will require an institution to assume a leadership role in the process (i.e., a muscular champion is needed). The research showed that government is the most likely institution to take the lead in standardizing shipping paper format. Chapter 3: Findings and Applications Chapter 3 includes the process followed and results of Task 4: Submit a Draft Road Map and Task 5: Propose a Methodology for Proof-of-Concept Exercises, as well as the overall findings and a discussion of the applications of ESP. Chapter 3 describes both the benefits identified from successful implementation of ESP and the issues that are likely to create problems for augmenting or replacing the existing hazmat communication system. The project identified four major stakeholder groups, with differences in the findings related to each group. For example, some regulatory compliance personnel may be primarily involved with safety and others with security. Survey interviews asked participating carriers to estimate the total processing time or cost associated with their processing of hard copy shipping papers. Responses varied. Table S-1 provides a sample of responses that illustrate the range of impacts, depending on the level of automation and mode-specific processes and practices. It is unclear why the range of estimated impacts varies so greatly, particularly with the ocean carrier. Respondents felt that time would be saved by entering data once and then using it multiple times. Although hard copy shipping papers and emergency information for hazmat are required to be on the vehicles transporting them, having the data in the form of ESP allows the hard copies to be printed. The primary benefits to government will be through the streamlining of document (shipping paper) acquisition and review, as well as a reduction in data entry errors if ESP information can be integrated with roadside inspection software and other relevant reports to be completed such as crash and incident reports. After initial investments, there likely will be a reduction of operational costs through efficiency gains, particularly with the ability to move ESP data electronically to stakeholders on a need-to-know basis more quickly and accurately than is done today so that it may be acted upon more quickly. The quantification of such savings will depend greatly upon the level of process automation for the particular government entities and the type of solution(s) implemented. Regulatory benefits will depend on the modifications made or parameters established by oversight agencies to accept ESP as an alternative to hard copy papers. Impediments to the adoption of ESP relate predominantly to three areas. The first is cost. Carriers and shippers are concerned that the costs of instituting ESP will outweigh the benefits. The second is a concern that regulatory agencies will use ESP as a means to expand compli- ance. This could make transporting hazmat more expensive and difficult, and there is also concern that greater access to shipment information through a mandated, nationwide ESP system would risk exposing business-sensitive data to inadvertent disclosure. Third, both Respondent Estimate of Impact Air carrier 1 hour Air carrier 40 min – 1 hour, 40 min Integrator 5 min Ocean carrier minutes – hours Table S-1. Impact of processing time avoided by ESP over hard copy shipping papers.

8carriers and shippers express the fear that unless implementation is universal, some com- panies will be bearing additional costs that would be avoided by their competitors. There are also concerns that any mandated system may not be affordable to small operations, including those that service specialized needs or remote locations. Effective functioning of the system would be very difficult unless ESP is adopted universally. Stakeholders and User Needs Summary. Chapter 3 identifies the major stakeholders and user needs for the four primary stakeholder groups involved with ESP: shippers, carriers, regulatory agencies, and emergency responders. A single hazmat shipment from its origin to destination may involve intermodal transportation and international border crossing(s), and otherwise may involve a number of the stakeholder groups. Shippers and carriers are more concerned with the commercial, logistical, freight management back-office nature of ESP benefits. Shippers (who may also be product manufacturers) offer hazmat for delivery to a consignee. They verify that the shipment complies not only with Title 49 of the Code of Federal Regulations (49 CFR) but also with other mode-specific regulations. Business operations need additional information such as on nonhazardous materials, other parties in the supply chain, billing and financial data, and expected delivery time. Carriers accept shipments and execute the contracted needs of the shipper, transporting the goods to the consignee or to an interline carrier (i.e., transfer to a different transportation carrier). Regulatory enforcement personnel need information with which to determine whether the hazmat shipment is compliant with safety requirements. Emergency responders primarily need specific information on the materials present, types of containers, and quantities of materials. Potential interaction of hazmat with other materials in the shipment is a concern to emergency responders. While it is not feasible to have information about chemical interactions in either electronic or hard copy shipping papers, ESP can otherwise help emergency responders by being available more quickly and to more organizations than hard copies when accessed remotely. Table S-2 characterizes the basic user needs for each primary stakeholder group. Stakeholder Group User Needs Shippers • In-transit visibility • Data sharing with supply chain partners • Regulatory compliance • Paperwork reduction/reduced administrative expense • Hazmat/dangerous goods shipping paper creation • Commercial information security Carriers • In-transit visibility • In-transit records compliance • Paperwork reduction/reduced administrative expense • Data sharing with authorized interlines • Record retention compliance • Bill of lading, manifest, and freight bill creation • Commercial information security • Anti-theft/-sabotage/-terrorism security Regulatory compliance • In-transit records compliance • Record retention compliance • Shipment, vehicle, and driver documentation Emergency responders • Specific information on materials present, types of containers, material quantities, and how to get timely expert information on potential interactions with other materials in the shipment • Awareness of product name • Emergency contact information • Receipt of information quickly and ideally at safe stand-off distance Table S-2. User needs characterization.

9 Existing Electronic Interchange Systems. One important contribution of the research was to identify and categorize types of electronic interchange systems. As part of the effort to identify best practices in place for ESP, many existing solutions were identified. These solutions were grouped into categories. The descriptions of the existing systems and examples follow. None of the specific commercial solutions are cited, but their functionality is described in general terms. These categories are: Direct partner-to-partner exchanges, in which trading partners agree on the format and method of information exchange and implement the exchange directly between the partners’ respective systems. The format and method of the information exchanged can take any form agreed to between the partners, but it is suggested that industry standards [e.g., EDI; extensible markup language (XML)] be adhered to in these implementations. Value-added networks (VANs), in which trading partners use a third-party forwarding or translation service to facilitate the exchange of information between parties, such that each party can maintain its existing document format. The VAN serves to receive a docu- ment or file from one trading partner in that partner’s preferred electronic format, trans- late the data as necessary into a format that the receiving partner can read, and forward the document to the receiving party or parties. Hosted systems, in which all data intake takes place under a single, often centralized sys- tem that allows for trading partners with little information technology infrastructure to participate in e-commerce-type activities. A trading partner will typically log onto a service provider’s website to generate shipping documents, check status of shipments, and perform other functions. Variations, which include systems that are a combination of the previous approaches. For instance, a large retailer may conduct direct data exchanges with its top Tier 1 sup- pliers (i.e., suppliers that sell products directly to a company and thus are very high on that company’s chain of suppliers) but use a VAN to communicate with Tier 2 suppliers (i.e., suppliers that sell products to Tier 1 suppliers rather than directly to the company). Chapter 3 recognizes a number of current efforts that have relevance to ESP (see Section 3.2), such as: • PHMSA’s Hazardous Materials – Automated Cargo Communications for Efficient and Safe Shipments (HM-ACCESS) program, which is conceptually related to HMCRP Project 05, and • U.S. DOT’s Dynamic Mobility Applications (DMA) program, which seeks to identify, develop, and deploy applications that leverage the full potential of connected vehicles, travelers, and infrastructure. Within DMA, automated vehicle-to-infrastructure (V2I), vehicle-to-vehicle (V2V), and infrastructure-to-vehicle (I2V) communications could play a significant role in the future of ESP. Chapter 4: Conclusions Chapter 4 suggests a path forward for the use of ESP for hazmat shipments. The analysis concludes that much of what needs to be in place to realize a standards-based ESP solution already exists. Table S-3 summarizes, in stoplight format, the state of readiness of eight key elements. While most components are displayed as yellow (Y), only one component, displayed as red (R), signifies a major hurdle. Chapter 4 suggests that efforts such as the International Vessel Operators Dangerous Goods Association’s (IVODGA’s) Removing Intermodal Impediments to Dangerous Goods & Hazmat Shipping program (see Subsection 3.3.2) and the International Air Transport Association’s (IATA’s) e-freight initiative (see Subsection 3.3.1) be referred to for valuable

10 lessons. Both efforts took a multimodal approach and gleaned useful information regard- ing the use of data elements in place across multiple modes. IVODGA prepared a detailed multi modal mapping of these elements in its 3.12 Shipping Paper worksheet of all modes. Both efforts have faced challenges in realizing broad acceptance and adoption, yet how and why these challenges arose and what these organizations have done to address them yielded lessons for hazmat ESP. Among these lessons is that of developing an approach and performance metrics that account for the business processes and improve efficiency of participants along the transportation information chain. Also, stakeholder education leading to broad acceptance and adoption is critical to move from research to practical application. The road map (i.e., path forward) will entail a multiphase, multiyear effort requiring sponsors and champions from the public sector and associations representing key modes. The key elements of this effort involve: • Development of standards for e-commerce and data elements; • Proof-of-concept tests, field tests, and pilots; and • Cost–benefit analyses. Approaches for ESP compliance may be developed that offer alternatives to electronic data exchange. Broad adoption that meshes with business processes and improves efficiency will need to incorporate electronic data exchange. Standards for e-commerce, including data elements, must be established in the path forward. As shown in Table S-3, interoperability with other e-commerce systems remains a key hurdle, while the standards needed to support ESP solutions have already been covered by IVODGA and IATA. A series of proof-of-concept exercises, field testing, and operational pilots should be conducted to assess the feasibility and functionality of alternative approaches. This report *R/Y/GssenidaeRtnemelEssenidaeR Stakeholder buy-in Shippers and carriers must see a positive net cost– benefit ratio before adoption is likely. Challenges to data privacy and sensitivity must be overcome before regulators and emergency responders can expect to benefit. Y Data entry requirements A data dictionary must be selected and subsequently extended to handle hazmat information. Y Information flow parameters/limits Interfaces that enable the integration of ESP with existing business-to-business (B2B) applications and open standards must be developed/adopted. Y Support of multimodal shipments Marine and air have begun moving down the path of multimodal standards. Rail’s use of Standard Transportation Commodity Code (STCC) is a critical barrier. Y Degree of in-transit visibility This visibility is dependent on the willingness of partners to share information as well as the timeliness and availability of the data. Y Adequacy of standards Standards exist to support nearly all aspects of an ESP solution, and it is simply a matter of choosing which best serves the user needs. G Interoperability with other electronic commerce systems A multitude of current, disparate systems and no specific mandate to change preclude this from being readily implementable. R Data/communications security Current security standards and best practices implemented in other industries are adequate to support e-commerce and ESP needs. G *G = Green, Y = Yellow, R = Red Table S-3. ESP implementation state of readiness.

11 provides a detailed methodology for the proof-of-concept exercises designed to test imple- mentation strategies and functionality. The proof-of-concept exercises will be the first phase, and subsequent tests will narrow feasible options to those most likely to meet the goals and performance objectives of the ESP. Cost–benefit analyses should attend each test phase to ensure that practical and imple- mentable solutions that meet business-level returns on investment (ROIs) are being sought. Industry will not accept unfunded mandates or approaches that provide benefits to one segment of participants while driving up the cost of another segment. In terms of the road map, Table S-4 shows key milestones that need to be achieved for implementation of ESP. These are essentially sequential, although some overlap should be possible. With an aggressive approach, it may be possible for pilot ESP implementations to be underway within a decade. Summary and Conclusions The key to implementing hazmat ESP for the benefit of all of its major stakeholder groups and for multimodal shipments is solving the larger challenges of e-commerce. E-commerce is currently being used successfully by groups using electronic document submission. However, for hazmat stakeholders these successful examples have developed largely in isolation from other modes and stakeholders, and there is no common standard with adequate guidance to allow them to have the desired compatibility across multimodal domains. For ESP to be successful as an alternative to hard copy shipping papers, data need to be entered once and reused to the greatest extent. To achieve that, entry of electronic data into ESP needs to start with the shipper to provide sufficient continuity throughout the shipment’s life cycle and meet the potential of ESP. Origination with the shipper is not currently occurring to a significant extent, which is a large obstacle that must be resolved to achieve success. Near mreT-gnoLmreT-diMmreT- Action/ milestone Identify champion for ESP effort Review and consolidate products of prior related efforts (e.g., IATA e-freight, IVODGA’s Removing Intermodal Impediments to Dangerous Goods & Hazmat Shipping, HM- ACCESS) Facilitate meetings of ESP stakeholder organizations Discuss e-commerce standard(s) and data elements applicable to ESP Conduct initial cost–benefit analyses on elements of ESP implementation Conduct sponsored proof- of-concept test(s) Identify conceptual ESP system Conduct cost– benefit analyses on conceptual ESP system Reach agreement on required ESP data elements Define e-commerce standard(s) applicable to ESP Accept e-commerce standard applicable to ESP Conduct field tests of prototype ESP system Conduct limited and wider field tests of ESP standard and system Enact guidance Conduct pilot implementations involving all transportation modes (i.e., highway, rail, marine, and air) Table S-4. Timeline (outline for a path forward).

12 When identified issues and impediments have been addressed, the following benefits can be expected to accrue from the adoption of ESP: • Improved accuracy and advanced notification of shipping paper information. This could also improve safety by helping ensure that a particular facility is adequately equipped to receive a certain hazmat. • Improved safety by being able to obtain access to ESP when the paper copies are unavailable. A costly delay could occur when shipping papers are destroyed or inaccessible due to the aftermath of a serious hazmat spill resulting from a tank truck crash or rail tank car derailment. • Protection of security-sensitive and business-sensitive information through advanced processing techniques and commercial encryption practices. Potential users will be more accepting of ESP’s efficiencies and communications advantages when they are sure that sensitive data will be protected. • Cost savings. When total costs are aligned, savings should be achievable. For example, paper copies can be printed from highly accurate ESP as opposed to ESP resulting from laborious electronic keying of information from the paper copies by a stakeholder that does not realize a benefit. • Access to ESP by emergency responders and roadside inspection personnel through pre-arranged permissions appropriate to their need. This will allow quicker access to the information on the shipping paper, including emergency-response-related information that can supplement services already available to help emergency responders. • Improved transferability of hazmat shipping information to other modes, facilitating interlining. When shipments are split up en route, electronic signatures and approvals can help reduce confusion and provide greater visibility into timing and composition of the material to be delivered to the consignee. Despite the identified challenges of implementing ESP, there are no substantive logical or legal impediments involved. However, the research shows that a single solution that will meet the needs of all stakeholder groups to an appreciable degree would be very difficult and costly to achieve, and for it to even be possible a number of trade-offs must be considered. Thus, the research implies the need for a unified ESP system view that supports interoperability and exchange of standardized electronic commerce for hazmat transportation of all carrier modes, carrier types, and hazmat classes without duplicate data entry. The aforementioned benefits can be achieved through voluntary action. This will require cooperation and commitment among the stakeholders. The private sector is most concerned with business efficiency and cost savings. Industry knows the most appropriate technology solutions and standards that should be applied to the challenge and can effectively imple- ment them. While voluntary efforts are preferred, if regulation involving ESP is pursued, ESP adopters should not be penalized. Trade associations and other stakeholder organizations can help define ESP implementation goals to benefit the hazmat transportation community and advance the interests of their members. Key stakeholder groups could be aligned to sponsor and conduct the proof-of- concept exercises, participate in collaboration to help promote achievable goals along the path to ESP implementation, and encourage participation in a global ESP implementation process.