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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #01-0176 ([William Quade])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: William Quade

Location State: DC Country: US

View the Interpretation Document

Response text:

Date:    AUG 30, 2001                    Reply to Attn of    Ref. No. 01-0176

Subject:     INFORMATION: Request for Interpretation of 49 CFR 172.604

From:    Edward T. Mazzullo, Director
Office of Hazardous Materials (OHM-I 0)

To:    William Quade
Chief, Hazardous Materials Division FMC SA

This is in response to your request for clarification of § 172.604. Your questions are paraphrased and answered as follows:

Ql. What is the maximum allowable elapsed time from the time an emergency response call is placed, until the caller receives the required information?

AI. Section 172.604(a) requires that the emergency response telephone number be the
number of a person who is either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material, or has immediate access to a person who possesses such knowledge and information. The term "immediate access" is not defined in the HMR. However, the term is intended to indicate that the emergency response information must be provided to a responder without undue delay. Clearly, a few minutes may elapse during a telephone call while the person answering the emergency response telephone number locates specific information on a particular product or contacts a person with that information. However, any delay longer than a few minutes would be unacceptable.

Q2. May the caller be referred to another telephone number?

A2. The answer is no. Providing another telephone number, without providing the required
response information or connecting the emergency responder to a knowledgeable person, does not fulfill the requirements in § 172.604.

Q3. The emergency responder is told that someone will call them back in ten minutes. Is that

A3. The answer is-no. "Call backs” regardless-of time parameters, are unacceptable and do not satisfy the requirements in § 172.604.

Q4. Is there a maximum time that the caller should wait for the call to be answered, i.e., a
maximum number of rings?

A4. The answer is no.

Q5. Is it acceptable for the person answering the emergency response telephone number to
read verbatim from the Emergency Response Guidebook (ERG)?

A5. Merely reading the information from the ERG does not meet the requirements in
§ 172.604(a). The person answering the emergency response telephone number should have knowledge beyond the information contained in the ERG; that person should be knowledgeable of the hazards and characteristics associated with the hazardous material, be familiar with the terminology and subject matter, and be able to provide comprehensive emergency response and accident mitigation information for the material involved.

Q6. Is it acceptable for the person answering the phone to ask for a brand/common name
because that person cannot respond to the proper shipping name.

A6. As some products contain widely varying concentrations of a hazardous material, the
person answering the emergency response telephone number may ask for a trade name in order to provide the most appropriate information. Because the emergency responder placing the call may not have access to that information, the person answering the emergency response telephone number must be able to provide emergency response information based on the basic description on the shipping paper.



Regulation Sections

Section Subject
172.604 Emergency response telephone number