Are You Ready for a PHMSA Hazmat Inspection? Here’s What You Need to Know

Key Takeaway

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has released a new memo outlining inspection and enforcement priorities for hazmat shippers. The agency is focusing on high-risk sectors, undeclared materials, and repeat violations. Failing to comply can lead to significant penalties and increased oversight. Shippers must act now to review training, documentation, and emergency response protocols.

What does PHMSA’s new enforcement memo mean for hazmat shippers?

PHMSA's Office of Hazardous Materials Safety (OHMS) released a memo on November 20, 2025, outlining new priorities for hazmat inspections and enforcement. It shifts focus to high-risk sectors and data-driven targeting to prevent incidents and strengthen compliance.

This memo isn’t just a policy update. It’s a clear signal: companies that ship hazardous materials should expect more oversight, deeper inspections, and consequences for noncompliance. Now that you know what the memo says, let’s look at why it matters, and who’s most likely to get inspected.

Who is PHMSA targeting with their new inspection priorities?

PHMSA is prioritizing inspections for companies in specific categories, including:

• General hazardous material shippers
• Lithium battery shippers
• E-commerce businesses sending undeclared hazmat
• Cylinder and drum manufacturers
• Companies with past major violations

If your business falls into one of these areas, you're on the radar. The memo also highlights goals like helping shippers understand package selection and classification rules. In other words, you’re expected to get it right before a PHMSA inspector steps in. 

How does PHMSA enforce hazmat violations during inspections?

PHMSA doesn't just inspect, they take action, and they have a tiered system for how they respond to noncompliance. PHMSA uses several enforcement tools, with their recent memo highlighting three main options:

• Warning Letters: For probable violations that need correction. These usually come after issues like missing training records or minor documentation errors. They signal noncompliance but don’t carry immediate penalties.
• Tickets: For less serious violations without a major safety impact. For example, using outdated shipping papers or incorrect labels could lead to a ticket.
• Notices of Probable Violation (NOPV): For more serious cases, which can lead to civil penalties and formal hearings. This might be issued if undeclared hazmat causes an incident, or if past issues haven’t been fixed.

The penalty for each violation can reach up to $102,348 per incident, or $238,809 if it results in death, injury, or major property damage, according to federal law. Understanding how PHMSA enforces the rules helps, but it’s just as important to know what the biggest risks are right now.

What are the top compliance risks called out in the memo?

The top risks outlined in the memo line up with real-world compliance gaps PHMSA sees regularly:

1. Improper or missing hazmat classification: Mislabeling can result in incorrect handling and serious safety hazards.
2. Poor packaging or container selection: Packaging failures are a major cause of leaks and incidents in transit.
3. Missing or incorrect emergency response info: Shippers must provide a 24/7 phone number like CHEMTREC and accurate emergency data on shipping documents.
4. Undeclared lithium batteries or hazmat: E-commerce and consumer goods companies are especially at risk here. PHMSA shows that many lithium battery incidents come from undeclared shipments.

Each of these can trigger an inspection, a violation notice, or both. So what can you do today to reduce risk and stay compliant? Let’s break down the steps.

How can hazmat shippers prepare for a PHMSA inspection?

Based on the memo from PHMSA and existing regulations, here’s what you should double-check:

• Hazmat employee training:  Required every three years. Must cover function-specific and safety topics. Without current training, employees are more likely to make costly mistakes during packaging, handling, or documentation. CHEMTREC offers online training to help meet general and function-specific training requirements.
• SDS access and management: Safety Data Sheets (SDS) must be accessible and up to date. Inspectors often review SDSs to confirm your materials are correctly classified and communicated. CHEMTREC’s SDS Solutions team can create and manage SDS to help with compliance.
• Emergency response procedures: Must include a 24/7 phone number like CHEMTREC and trained personnel ready to answer. This isn’t optional, if no one picks up, it’s a violation.
• Packaging and labeling reviews: Check for compatibility, condition, and correct markings. Packaging is one of the most common failure points during inspections.
• Incident tracking and reporting: Know what triggers a DOT Form 5800.1 report and who is responsible. PHMSA will want to see that you’ve logged any releases and responded properly. CHEMTREC’s Incident Reporting service completes 5800.1 form reports and can submit them to PHMSA for you.

A proactive compliance review or mock audit could help uncover gaps before an inspector does. These exercises not only help fix issues, they show PHMSA that you're taking compliance seriously. But even with the best internal efforts, many companies need outside help to close the gaps. 

Who offers support to stay compliant with PHMSA regulations?

If PHMSA showed up tomorrow, would your team be ready? For many hazmat shippers, the answer is no, and the consequences can be costly. That’s why working with a trusted compliance partner isn’t just helpful, it’s essential.

CHEMTREC helps companies stay ahead of PHMSA inspections by building strong, defensible hazmat programs. They offer 24/7 emergency response coverage, SDS authoring and management, incident reporting, and regulatory training tailored to the exact risks outlined in PHMSA’s latest memo. Their specialists also support battery shipping compliance,, and even post-incident cleanup, giving you a complete solution from prevention to response.

With over 50 years of experience and partnerships with 80% of the world’s top chemical manufacturers, CHEMTREC knows how to help companies reduce risk, strengthen compliance, and protect their operations. Whether you're shipping chemicals, batteries, or consumer goods, CHEMTREC can help. make sure you’re inspection-ready.

Need help getting started? Talk to CHEMTREC today.