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Interpretation Response #06-0030 ([TEN-E Packaging Services, Inc.] [Mr. Robert J. Ten Eyck])

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

Interpretation Response Details

Response Publish Date:

Company Name: TEN-E Packaging Services, Inc.

Individual Name: Mr. Robert J. Ten Eyck

Location State: DC Country: US

View the Interpretation Document

Response text:

Feb 22, 2006

Mr. Robert J. Ten Eyck                     
Reference No. 06-0030
Director, Technical Services
TEN-E Packaging Services, Inc.
1666 County Road 74
Newport, MN 55055

Dear Mr. Ten Eyck:

This is in response to your December 14, 2005 letter requesting clarification regarding the emergency response telephone number requirements for hazardous materials as specified under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your scenario, you are a third party test lab that performed a test on a packaging containing a hazardous material that was shipped to you by your client. Specifically, you ask if the HMR allow for you to ship the hazardous material back to your client using the client’s emergency response telephone number.

In the scenario provided, you may use your client's emergency response telephone number by arrangement or agreement with the client. If the client uses a third party to provide emergency response telephone service, the third party provider must recognize that you are authorized to provide its telephone number on the shipping paper.

I hope this information is helpful.


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

172.604 (b), 173.22

Regulation Sections

Section Subject
172.604 Emergency response telephone number
173.22 Shipper's responsibility