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Interpretation Response #11-0008 ([J.J. Keller and Associates, Inc.] [Mr. Thomas J. Ziebell])

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

Interpretation Response Details

Response Publish Date:

Company Name: J.J. Keller and Associates, Inc.

Individual Name: Mr. Thomas J. Ziebell

Location State: WI Country: US

View the Interpretation Document

Response text:

June 9, 2011




Mr. Thomas J. Ziebell

J.J. Keller and Associates, Inc.

3003 W. Breezewood Lane

Neenah, WI 54957

Reference No. 11-0008

Dear Mr. Ziebell:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to emergency response telephone number requirements. Specifically, you ask whether § 172.604(b)(1) addresses shippers (offerors) providing their own emergency response telephone, number and whether § 172.604(b)(2) addresses offerors using an emergency response information (ERI) provider. You believe if this is so, the wording in § 172.604(b)(1), "contract number or other unique identifier assigned by an ERI provider," as added in the final rule HM-244C, "Minor Editorial Corrections and Clarifications" [75 FR 53593], published on September 1, 2010, should be removed to make the intent clearer. You also state that we did not make the corresponding HM-244C changes to § 172.201(d).

You are correct in your understanding of the intent of §§ 172.604(b)(1) and (b)(2). Section 172.604(b)(1) is intended to address the offeror also serving as the ERI provider, and paragraph (b)(2) is intended to address the offeror using a third party to serve as the ERI provider. We will revise § 172.604(b)(1) accordingly and also review § 172.201(d) for consideration of any necessary revisions in an upcoming rulemaking action.

Thank you for bringing this matter to our attention.


T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

172.604(b)(1), 172.201(d)

Regulation Sections

Section Subject
172.604 Emergency response telephone number