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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