The movement of dangerous goods through transportation channels has been the object of concern by private industries and governmental representatives for almost a century. Their movement creates risks, over which private and public control efforts have been exercised in various ways. A major control effort has been the development of Federal regulations prescribing conditions under which these goods may be offered for transportation and moved by the carrier.

Serious difficulties exist under these regulations. The regulations lack clarity and uniformity of stated purpose. Their development was not supported by consistent analytical approaches for determining the safety value of changes. They permit the existence of unrecognized variations in the level of risk and resultant cost of precautionary measures among modes and commodities. Neither the hazards or risks nor the scope of the consequences to be countered by the regulations are clearly delineated. The adequacy of the weight given to risk reduction for each segment of the populations at risk, as these regulations were developed, is uncertain. Trade-offs between alternative regulatory changes addressed to specific problems can not be identified or assessed. These difficulties arise from the lack of a uniform framework for analyzing the problems created by the movement of dangerous goods in our transportation systems. The scheme of the regulations focuses on the inherent nature of the dangerous commodities and their containment, rather than the risks created by dangerous goods movements in the transportation system.

Following the creation of the Department of Transportation in 1967, the initiative for promulgating changes in most of these regulations has been shifting from the regulated to the regulators. If difficulties existing under present regulations are to be satisfactorily resolved, the approaches under which current regulations were developed require reexamination. This need has been given cognizance by the Department of Transportation, but the new approaches suggested to date do not appear to fully resolve the difficulties described.

This study examines the salient approaches underlying the development of the existing regulations, describes the difficulties created thereby, and discusses the needs which must be met by new approaches. The study

includes an example of a type of framework which might be employed for effectively guiding the risk identification, risk evaluation, and risk reduction processes addressed to dangerous goods transportation.

The National Transportation Safety Board concludes that adoption of a risk-based framework for future dangerous goods regulations is necessary, desirable and feasible, and should be developed and implemented without undue delay.

The recommendations of the Safety Board appear on page 34.