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Interpretation Response #00-0352 ([Vinson & Elkins L.L.P.] [Mr. David Tuckfield])

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

Interpretation Response Details

Response Publish Date:

Company Name: Vinson & Elkins L.L.P.

Individual Name: Mr. David Tuckfield

Location State: TX Country: US

View the Interpretation Document

Response text:

February 14, 2001

 

Mr. David Tuckfield                      Ref.  No. 00-0352
Vinson & Elkins L.L.P.
One American Center, Suite 2700
600 Congress Avenue
Austin, TX 78701

Dear Mr. Tuckfield:

This is in response to your December 12, 2000, letter regarding emergency response telephone number requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 ­180).  Specifically you request clarification on the meaning of the term "immediate access to a person with detailed emergency response information.” You provide the following scenario in your letter:

The person answering the phone is not knowledgeable of the hazards and characteristics associated with the material that is the subject of the call, but is able to connect (e.g., patch) the caller to the person who can provide the information.  The person answering the phone may access the person with the information at their home via telephone or pager.

The scenario provided in your letter qualifies as “immediate access to a person with detailed emergency response information” if the person answering the phone accesses the person with the information via telephone.  If the person answering the phone must rely on a system that necessitates a “call back” (e.g., a pager) it is not in compliance with § 172.604.

I hope this satisfies your request.

Sincerely,

 

Edward  T. Mazzullo
Director, Office of Hazardous Materials Standards

 

172.604

Regulation Sections

Section Subject
172.604 Emergency response telephone number