Interpretation Response #10-0226 ([NACA Logistics (USA) Inc. dba Vanguard Logistics] [Mr. Eric Fischer])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: NACA Logistics (USA) Inc. dba Vanguard Logistics
Individual Name: Mr. Eric Fischer
Location State: CA Country: US
View the Interpretation Document
Response text:
January 5, 2011
Mr. Eric Fischer
Hazardous Materials Manager
NACA Logistics (USA) Inc. dba Vanguard Logistics
857 E. 230th Street
Carson, CA 90745
Ref. No.: 10-0226
Dear Mr. Fischer:
This responds to your October 20, 2010 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You refer to a letter issued by this office to DG Advisor (Reference No. 10-0029) pertaining to the changes to § 172.604 regarding the information that is required to accompany the emergency response telephone number. Specifically, in the sample shipping papers that you provided you pose two scenarios and ask if they meet the requirement in § 172.604(b)(1) for the name of the person identified with the emergency response telephone number to be entered on the shipping paper in a prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found.
Your scenarios are restated as follows:
Scenario 1. Acme Inc is registered with the ERI provider. "Acme Inc" is shown in the Shipper/Consignor/Sender Box of the standard IMO Dangerous Goods Declaration. "Acme Inc" is also shown in the Name of Company Preparing Note Box. The only other company name on the shipping paper is listed in the Consignee Box. The ERI Provider name and phone number is in the Additional Handling Information Box.
Scenario 2. Acme Inc is registered with the ERI provider. "Acme Inc" is shown in the Shipper/Consignor/Sender Box of the standard IMO Dangerous Goods Declaration. "Haz Experts Inc." is shown in the Name of Company Preparing Note Box. The only other company name on the shipping paper is listed in the Consignee Box. The ERI Provider name and phone number is in the Additional Handling Information Box.
As shown in the two examples you provided, the placement of "Acme Inc" on the standard IMO Dangerous Goods Declaration is consistent with the requirement in § 172.604(b)(1) in that it is
prominent, readily identifiable, and clearly visible in the first box on the form.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
172.604
Regulation Sections
Section | Subject |
---|---|
172.604 | Emergency response telephone number |