Interpretation Response #06-0056 ([NACA Logistics] [Mr. Eric Fischer])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 03/30/2006

Company Name: NACA Logistics

Individual Name: Mr. Eric Fischer

Location State: IL Country: US

View the Interpretation Document

Response text:

Mar 30, 2006

Mr. Eric Fischer                 Reference No. 06-0056
NACA Logistics
1477 Hamilton Parkway
Itasca, IL 60143

Dear Mr. Fischer:

This is in response to your February 27, 2006 letter asking us to confirm the accuracy of an answer we provided in a February 21, 2001 letter to Garry Howell of the Overnight Transportation Company concerning whether or not a shipper may enter more than one emergency response telephone number on a shipping paper for a hazardous materials shipment under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your example, you state you receive some bills of lading with two emergency response telephone numbers accompanied by wording stating one number is available from “8:00 AM to 5:00 PM” and the other is available all other times.

The answer is yes. More than one emergency response telephone number may be entered on a shipping paper and the numbers may be active for different times provided that ‘together they satisfy the requirements prescribed in § 172.604(a) that an emergency response telephone number be monitored at all times the hazardous material is in transportation, including storage incidental to transportation. The person monitoring the number must be knowledgeable of the characteristics of the hazardous material and have comprehensive emergency response information about the material, or immediate access to a person who possesses such knowledge and information. See § 172.604(a)(1) and (a)(2). Although the HMR do not currently state the shipper is required to provide the time period for which an emergency response telephone with a limited time is available, it is the opinion of this Office that the shipper should clearly state the time period the number is available and to which number the restricted time applies.

I hope this information is helpful.

Sincerely,

Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office f Hazardous Materials standards

172.604(a)

Regulation Sections