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Interpretation Response #09-0007 ([Mr. Joseph A. Taranovich] [American Honda Motor Company])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mr. Joseph A. Taranovich

Individual Name: American Honda Motor Company

Location State: OH Country: US

View the Interpretation Document

Response text:

March 10, 2009









Mr. Joseph A. Taranovich

American Honda Motor Company

25000 Honda Parkway

Marysville, Ohio   43040


Ref. No. 09-0007


Dear Mr. Taranovich:


This responds to your December 18, 2008 letter requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to EX numbers and emergency response telephone numbers.  Your questions are paraphrased and answered below.


According to your letter, your company assists in retrieval of "live" inflators, modules, or pretensioners (UN 3268, Class 9) for analysis by your company, Honda factories, or suppliers.  The inflators, modules, and pretensioners are manufactured by various suppliers for Honda.  The supplier applies for an approval from the Associate Administrator for Hazardous Materials Safety and forwards the assigned EX number to your company for your records and shipping documents. 


Q1. Is a shipper required to retain a copy of the approval letter for products it places in transportation? 


A1.  No.  Only the person applying for the approval is required to retain a copy of the approval letter.  However, you may wish to obtain a copy of the approval from the supplier.  You may also obtain a copy of the approval from PHMSA"s Office of Hazardous Materials Special Permits and Approvals at 202-366-4535.  In addition, we are in the process of making the competent authority/approvals available at our web site: 


Q2.  Must an EX number be marked on the outside of the package?


A2.   No.  Marking requirements in §172.320 do not apply to your UN3268, Class 9 product.  EX numbers are required to be marked on packages containing explosive materials in accordance with §172.320.  For approved inflators, modules, or pretensioners, the shipping paper must include the EX number or product code in association with the basic shipping description.  Product codes must be traceable to the specific EX number assigned.   See §173.166(c).  When the EX number is provided on the shipping paper, it need not also be marked on the package. 


Q3.  We contract with a third-party emergency services company for 24-hour emergency telephone service in accordance with § 172.604.  May another entity use our emergency contact telephone number if we are not the shipper or recipient indicated on the shipping papers?


A3.  In accordance with § 172.604, a person who offers a hazardous material for transportation must provide an emergency response telephone number for use in the event of an emergency involving the hazardous material.  The telephone number must be the number of the offeror or the number of an agency or organization capable of, and accepting responsibility for, providing detailed information about the hazardous material.  Another entity may use your emergency response telephone number by prior arrangement with you and the third-party provider.  The emergency response provider may require evidence, such as your company name or registration number, indicating that your company contracted for the emergency response services.   An indication of this contractual relationship on the shipping paper will promote linkage between the provider and the person arranging to use the provider"s service, ensuring compliance with § 172.604.   Accordingly, a person who arranges with an organization to provide emergency response services required by the HMR should ensure that the shipping papers that accompany the shipment include the information necessary to enable the provider to identify the person who has contracted for the services. 


I hope this answers your inquiry.






Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


173.166, 172.604, 172.320


Regulation Sections

Section Subject
172.604 Emergency response telephone number
173.166 Safety devices