Hazmat Compliance & Safety Update: 2025 Year in Review

Hazmat Compliance & Safety Update: 2025 Year in Review

The following highlights summarize the most important U.S. and international changes that every hazmat professional should know heading into 2026.

USA Regulatory Updates

PHMSA’s New Data-Driven Enforcement Strategy

On November 20, 2024, PHMSA issued a landmark memorandum outlining its inspection and enforcement priorities for the coming year. Moving away from random inspections, the agency is shifting toward a "data-driven" approach, utilizing advanced analytics to identify high-risk shippers and undeclared shipments before they cause incidents. The memo explicitly highlights a focus on repeat offenders ("recidivism") and packaging integrity, signaling that companies with gaps in their data or prior violations can expect heightened scrutiny in 2025. Read the full memo here: PHMSA Hazardous Materials Enforcement Priorities Memo (Official PDF).

PHMSA — Package of 17 NPRMs (HMR Modernization)

PHMSA published a large set of proposed rulemakings intended to modernize and reduce burdens in the Hazardous Materials Regulations; shippers should scan these NPRMs for positive impacts on special permits, packaging, and paperwork reduction. This "deregulatory" package is a rare opportunity for industry to support rules that lower costs without compromising safety. View the proposals on the PHMSA Rulemakings & Notices (Federal Register) page.

PHMSA — Emergency Response Guidebook (ERG) 2024 Availability

The 2024 ERG and mobile app were released for first responders — make sure your incident plans and driver route packets reference the current ERG guidance. Access the resources on the PHMSA Emergency Response Guidebook (ERG) 2024 page.

PHMSA - Registration Fee Update

Budgeting for compliance may get easier—at least for now. PHMSA has withdrawn its proposed rulemaking that would have increased the annual Hazardous Materials Registration fees for persons who transport, or offer for transportation, certain categories and quantities of hazardous materials. While this temporarily preserves current flat-rate fees for both small businesses and large registrants, it’s still a good time to review your registrations and stay prepared for any future updates. Review the official Hazmat Registration Process overview here

EPA TSCA: The Sleeping Giant of Compliance

While DOT rules grab headlines, the EPA’s Toxic Substances Control Act (TSCA) is generating significant risk for chemical distributors in 2025. With aggressive new bans on solvents like Trichloroethylene (TCE) and stricter "Significant New Use Rules" (SNURs), hazmat shippers must ensure their products are not just safe to transport, but legal to sell and use at the destination. Find more details in the EPA’s Risk Management & TSCA Implementation update.

OSHA Hazard Communication: Still the #1 Violation

Despite being a mature regulation, OSHA’s Hazard Communication Standard remains a top source of fines. In 2025, inspectors are zeroing in on the accuracy of Safety Data Sheets (SDS) and the "downstream" training of employees. It is no longer enough to just have an SDS; the data must match the label, and the employees must understand the specific hazards, or companies face maximum penalties per violation. Consult the OSHA Enforcement: Hazard Communication Trends report.


International & Standards

IATA / ICAO — Updated Lithium Battery Guidance

IATA published updated guidance tied to the 66th Edition and ICAO Technical Instructions that clarifies handling of newer battery chemistries, cargo tracking devices, and common air-transport questions. If you ship batteries by air, this is mandatory reading to navigate the complexities of the new year. Review the IATA Lithium Battery Guidance Document – 2025.

GHS Revision 11: Recognizing "Global Warming Potential"

The Globally Harmonized System (GHS) continues to evolve, with Revision 11 introducing a new hazard class for chemicals that contribute to global warming. While US adoption often lags behind the UN release, global shippers need to prepare for these changes now. This revision also emphasizes non-animal testing methods for skin sensitization, reflecting a modernization of hazard classification that will eventually impact Safety Data Sheets (SDS) worldwide. Learn about the UN GHS Revision 11 Released: Key Updates You Need to Know.

Back to blog

Leave a comment