Interpretation Response #11-0008 ([J.J. Keller and Associates, Inc.] [Mr. Thomas J. Ziebell])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: J.J. Keller and Associates, Inc.
Individual Name: Mr. Thomas J. Ziebell
Location State: WI Country: US
View the Interpretation Document
Response text:
June 9, 2011
Mr. Thomas J. Ziebell
J.J. Keller and Associates, Inc.
3003 W. Breezewood Lane
Neenah, WI 54957
Reference No. 11-0008
Dear Mr. Ziebell:
This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to emergency response telephone number requirements. Specifically, you ask whether § 172.604(b)(1) addresses shippers (offerors) providing their own emergency response telephone, number and whether § 172.604(b)(2) addresses offerors using an emergency response information (ERI) provider. You believe if this is so, the wording in § 172.604(b)(1), "contract number or other unique identifier assigned by an ERI provider," as added in the final rule HM-244C, "Minor Editorial Corrections and Clarifications" [75 FR 53593], published on September 1, 2010, should be removed to make the intent clearer. You also state that we did not make the corresponding HM-244C changes to § 172.201(d).
You are correct in your understanding of the intent of §§ 172.604(b)(1) and (b)(2). Section 172.604(b)(1) is intended to address the offeror also serving as the ERI provider, and paragraph (b)(2) is intended to address the offeror using a third party to serve as the ERI provider. We will revise § 172.604(b)(1) accordingly and also review § 172.201(d) for consideration of any necessary revisions in an upcoming rulemaking action.
Thank you for bringing this matter to our attention.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.604(b)(1), 172.201(d)
Regulation Sections
| Section | Subject |
|---|---|
| 172.604 | Emergency response telephone number |