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.
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 is focusing on three key areas: outreach, inspections, and enforcement standards.
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.
PHMSA’s inspections now focus on operations that present the highest safety risk or recurring compliance concerns. Priority targets include:
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.
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.
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:
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.
Don’t wait for PHMSA to discover gaps. Here’s how to evaluate readiness:
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.