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Interpretation Response #02-0179 ([URS Corporation] [Andrew N. Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Andrew N. Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

Jul 11, 2002

Mr. Andrew N. Romach                  Reference No. 02-0179
Corporate Regulatory Manager
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC 27560

Dear Mr. Romach:

This is in response to your letter regarding emergency response information required by § 172.602 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if the Emergency Response Drill (ERG) Code listed in Column N of Section 4.2, List of Dangerous Goods, in the International Civil Aviation Organization Technical Instructions, ["Column N" is actually in the International Air Transportation Association (IATA) Dangerous Goods Regulations] satisfies the emergency response information requirements in § 172.602 of the HMR.

The answer is no, the ERG Code by itself does not meet the emergency response information required by § 172.602(a) of the HMR.  The code which consists of a combination of numbers and letter includes neither the basic description and technical name of the material nor the emergency response information.  However, the IATA Dangerous Goods Regulations in Section 4.1.6.14, under "Column N", refers persons to ICAO's "Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods" for explanation of the ERG Code.  Section 172.602(b)(3)(iii) of the HMR authorizes use of the ICAO Emergency Response Guidance aboard aircraft or other equivalent documents to meet the emergency response information requirements for a separate document.

I hope that this information is helpful.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

172.602(a)

Regulation Sections

Section Subject
172.602 Emergency response information