On Monday, May 4, the National Energy & Fuels Institute (NEFI) filed formal comments with the Pipeline and Hazardous Materials Safety Administration (PHMSA) in response to the agency's request for information on the safety risks of transporting hazardous materials in heavy-duty electric vehicles.

PHMSA opened the docket (PHMSA-2025-0678) on February 2 to gather input on how the transition from internal combustion engine (ICE) motor carriers to electric vehicles may affect hazmat packaging integrity, transportation safety, emergency response protocols, and overall vehicle risk. The agency indicated it may use the responses to scope further research into hazmat transportation in EVs.

The NEFI comments, prepared in coordination with the National Propane Gas Association (which also submitted comments), focus on the unique fire and thermal runaway risks posed when flammable or combustible cargo tanks are mounted on electric vehicles. The letter notes that MC-331 pressurized tanks used for propane and MC-306 non-pressurized tanks used for heating oil, kerosene, and diesel have decades of testing experience on ICE vehicles but have not been evaluated on EV platforms by state or federal authorities.

NEFI and NPGA both raised concerns that current emergency response protocols, which generally allow EV battery fires to burn themselves out, are incompatible with the presence of a flammable or combustible cargo tank, where the risk of a Boiling Liquid Expanding Vapor Explosion (BLEVE) or tank impingement is unacceptably high.

The comments build on a joint NEFI-NPGA letter sent to PHMSA in November 2024 that raised these concerns in the context of state-level electrification mandates. The PHMSA docket grew out of that earlier request for guidance.

Read NEFI’s letter to the PHMSA here.

For more information on this issue, contact NEFI Regulatory Counsel Rick Schweitzer at rpschweitzer@rpslegal.com.