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Interpretation Response #10-0029 ([DG Advisor, LLC] [Mr. Ben Barrett DG Advisor, LLC])

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

Interpretation Response Details

Response Publish Date:

Company Name: DG Advisor, LLC

Individual Name: Mr. Ben Barrett DG Advisor, LLC

Location State: MO Country: US

View the Interpretation Document

Response text:

March 29, 2010




Mr. Ben Barrett

DG Advisor, LLC

1924 East Blue Ridge Blvd.

Kansas City, MO 64146

Reference No. 10-0029

Dear Mr. Barrett:

This is in response to your e-mail and telephone conversation with a member of my staff regarding the HM-206F final rule, "Revision of Requirements for Emergency Response Telephone Numbers" published on October 19, 2009 in the Federal Register [74 FR 53413]. (A correction to the final rule's effective date was published on October 22, 2010 [74 FR 54489].) Specifically, you ask us to clarify the exception to the requirement for the name of the person registered with the emergency response information (ERI) provider to be entered in association with (immediately before, after, above or below) the emergency response telephone number on shipping papers.

The HM-206F final rule requires a shipping paper to identify the offeror of the shipment when an ERI provider is used to comply with the requirements of § 172.604. The final rule provides an exception in § 172.604(b)(1) to this requirement. The name of the person registered with the ERI provider is not required to be entered on the shipping paper in association with the ER telephone number if the name of the person is entered elsewhere on the shipping paper in a prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found. Therefore, provided the registrant's name is already entered elsewhere in this manner, there is no requirement to add the name twice. We will revise the regulatory text to clarify this issue in a future rulemaking.

I hope this information is helpful. Please contact this office should you have additional questions.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.604 Emergency response telephone number