Interpretation Response #10-0262 ([Veolia ES Technical Solutions, L.L.C.] [Mr. Tom Baker Director])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Veolia ES Technical Solutions, L.L.C.
Individual Name: Mr. Tom Baker Director
Location State: NJ Country: US
View the Interpretation Document
Response text:
February 15, 2011
Mr. Tom Baker
Director, Environment and Transportation
Veolia ES Technical Solutions, L.L.C.
1 Eden Lane
Flanders, NJ 07836
Ref. No. 10-0262
Dear Mr. Baker:
This responds to your December 14, 2010 letter requesting clarification on emergency response telephone number requirements in § 172.604 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provide examples of manifests where the generator/offeror is "ABC Company, Inc" while the person registered with the emergency response information provider (ERI provider) for these shipments is a different company, "VESTS". "VESTS" is also the unique identifier assigned by the ERI provider. Specifically, you provide scenarios and ask for verification that they comply with §§ 172.604(a)(3)(ii) and 172.604(b)(2) requirements. Your scenarios are restated as follows:
Scenario 1: In the case where the generator/offeror identified on the manifest is also the ERI provider, by entering the emergency response telephone number in Item 3 of the manifest and the generator"s/offeror"s name in Item 5 of the manifest, you ask if the shipping paper is in compliance with §§ 172.604(a)(3)(ii) and 172.604(b)(1) with respect to the display of the emergency information.
Scenario 2: In the case where the generator/offeror identified on the manifest is not the person registered with the ERI provider, by entering the emergency response phone number in Item 3 of the manifest and a statement in Item 14 of the manifest identifying the person who is registered with the ERI provider, you ask if the shipping paper is in compliance with §§ 172.604(a)(3)(ii) and 172.604(b)(2) with respect to the display of the emergency response information.
As shown in the two examples of manifests you provide, the placement of the emergency response telephone number and contact information is consistent with requirements in §§ 172.604(a)(3)(ii) and
172.604(b)(1) for Scenario 1 and §§ 172.604(a)3)(ii) and 172.604(b)(2) for Scenario 2.
I trust this answers your inquiry. If you need additional assistance, please contact this office at
202-366-8553.
Sincerely,
Ben Supko
Acting Chief, Standards Development
Standards and Rulemaking Division
172.604
Regulation Sections
| Section | Subject |
|---|---|
| 172.604 | Emergency response telephone number |